Privacy & Policy

1. IMPORTANT INFORMATION AND WHO WE ARE

1. 1.1 Purpose of this Privacy Policy
   • This privacy notice explains how ADDVantage Digital Solutions Limited (“healthya ConX”, “we”, “us”, “our”) collects, uses, shares, and safeguards your personal data, including any data you provide when using our platform, submitting consultations for review, or interacting with our website and services. It also informs you of your privacy rights and how the law protects you, including specific consent requirements for NHS data sharing and clinical services.
2. 1.2 Controller
   • ADDVantage Digital Solutions Ltd (Company No. 07112339) is the data controller for your personal data unless otherwise stated. healthya ConX is a wholly owned subsidiary of ADDVantage Digital Solutions Ltd, Clive House, Clive Street, Bolton, BL1 1ET, United Kingdom.
   • We are registered as a data controller with the Information Commissioner's Office (ICO) under registration number ZB860085.
   • Data Protection Officer (DPO):Simon GreenEmail: dpo@healthya.co.uk All clients based in the European Union or the UK, we have an appointed Representative:ADDVantage Digital Solutions Ltd, Clive House, Clive Street, Bolton, BL1 1ETEmail: CS@healthya.co.uk
3. 1.3 Contact Details
   • If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us at dpo@healthya.co.uk.
   • 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 (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.
4. 1.4 Changes to the Privacy Notice and your Duty to Inform us of Changes
   • This version was last updated in June 2025 and historic versions can be obtained by contacting us.
   • 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 your relationship with us.
5. 1.5 Third Party Links
   • This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

2. THE DATA WE COLLECT ABOUT YOU

1. Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
2. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
   • Identity Data: includes first name, last name, username or similar identifier, title, professional registration numbers (GPhC, GMC, NMC), date of birth, and gender.
   • Contact Data: includes billing address, delivery address, email address, telephone numbers, and practice or pharmacy address.
   • Professional Data: includes role, employer, qualifications, clinical specialisms, and professional indemnity insurance details.
   • Patient Data (Special Category Data): includes health and medical information, consultation notes, prescriptions, diagnoses, treatment history, Patient Suitability Questionnaire (PSQ) responses, NHS number, and patient contact details.
   • NHS Data: includes information derived from NHS systems including patient registration data, prescription data, clinical coding, and service utilisation metrics.
   • Clinical Review Data: includes data relating to consultations submitted for independent clinical review, including anonymised clinical assessments and prescribing decisions.
   • Technical Data: includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our platform.
   • Transaction Data: includes details about payments to and from you, payment card details (processed by third-party providers), billing records, consultation fees, and other details of services you have purchased from us.
   • Usage Data: includes information about how you use our platform, products and services, including consultation types, feature usage, and interaction logs.
   • Marketing and Communications Data: includes your preferences in receiving marketing from us and our third parties and your communication preferences.
   • Consent Records: includes detailed records of all consents obtained for various data sharing and processing activities.
   • Audit and Compliance Data: includes records maintained for regulatory compliance, professional oversight, and quality assurance.
3. 2.1 Special Categories of Personal Data
   • We process health data and other special categories of personal data as defined by Article 9 UK GDPR. This includes patient health information, clinical records, and any data revealing physical or mental health conditions.
   • We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
4. 2.2 If you fail to Provide Personal Data
   • Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.
5. 2.3 Patient Data
   • This relates to patient data you input into healthya ConX systems in order to use our services as set out in the contract between us. You remain the Data Controller and healthya ConX is the Data Processor in respect of this data. healthya ConX's sub-processors with access to patient data include AWS (hosting), Twilio (SMS), and contracted clinical reviewers.
   • We confirm that any international transfers of patient data will be carried out in compliance with the UK GDPR and Data Protection Act 2018, including use of the Information Commissioner's Office's International Data Transfer Agreement and Addendum, in force 21st March 2022, where required.
   • Patient data will be retained for the term of the contract between us and deleted in accordance with NHS Records Management Code requirements upon termination for whatever reason.

3. HOW IS YOUR PERSONAL DATA COLLECTED

1. We use different methods to collect data from and about you including through:
2. 3.1 Direct Interactions
   1. You may give us your Identity, Contact, Professional, and Patient Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
   2. 3.1.1 Apply for our products or services;
   3. 3.1.2 Create an account on our platform;
   4. 3.1.3 Subscribe to our service or publications;
   5. 3.1.4 Request marketing to be sent to you;
   6. 3.1.5 Enter a competition, promotion or survey;
   7. 3.1.6 Give us feedback or request support;
   8. 3.1.7 Submit consultations or request clinical review;
   9. 3.1.8 Provide specific consents for NHS data sharing and clinical services;
   10. 3.1.9 Participate in clinical governance or quality improvement activities.
3. 3.2 Automated Technologies or Interactions
   • As you interact with our platform, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our Cookie Policy in Section 11 for further details.
4. 3.3 Third Parties or Publicly Available Sources
   1. We may receive personal data about you from various third parties and public sources as set out below:
      1. Technical Data from the following parties:
      2. 3.3.1 Analytics providers such as Google based outside the UK;
      3. 3.3.2 Search information providers such as Google based outside the UK.
      4. Identity and Contact Data from the following sources:
      5. 3.3.3 Data brokers or aggregators such as healthcare industry databases based outside the UK;
      6. 3.3.4 Publicly available sources such as Companies House, professional registers (GPhC, GMC, NMC), and pharmacy/clinic websites;
      7. 3.3.5 NHS systems including NHS Spine, NHS England, NHSBSA, and Integrated Care Boards;
      8. 3.3.6 PMR systems (EMIS Health, Phoenix, Positive Solutions);
      9. 3.3.7 Payment processors (e.g., Stripe);
      10. 3.3.8 Independent clinical reviewers and contracted healthcare professionals.

4. HOW WE USE YOUR PERSONAL DATA

1. We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
   • Where we need to perform the contract we are about to enter into or have entered into 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.
   • Where you have provided explicit consent.
   • Where processing is necessary for the performance of a task carried out in the public interest.
   • Where processing is necessary to protect vital interests.
   • Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us at dpo@healthya.co.uk.
2. 4.1 Purposes for which we will Use Your Personal Data
   • We have set out below a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
   • Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground, we are relying on to process your personal data where more than one ground has been set out in the table below.
3. 4.2 Marketing
   1. We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
   2. Promotional Offers from Us
      • We may use your Identity, Contact, Technical, Usage and Professional Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
      • You will receive marketing communications from us if you have requested information from us or purchased services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
   3. Third-Party Marketing
      • We will get your express opt-in consent before we share your personal data with any company outside of healthya ConX for marketing purposes.
   4. Opting Out
      • You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at dpo@healthya.co.uk at any time.
      • Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase or other transactions.

1. 4.3 Cookies
   • You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this platform may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy in Section 11.
2. 4.4 Change of Purpose
   • We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at dpo@healthya.co.uk .
   • If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
   • Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. DISCLOSURES OF YOUR PERSONAL DATA

1. 5.1 We may have to share your personal data with the parties set out below for the purposes described in Section 4:
   1. 5.1.1 External third parties as set out in the Glossary.
   2. 5.1.2 NHS England, NHSBSA, ICBs, CQC, GPhC, GMC, NMC, and other regulatory authorities for compliance, claims, reporting, safeguarding, and audit purposes.
   3. 5.1.3 Service providers acting as processors who provide IT and system administration services.
   4. 5.1.4 Professional advisers acting as processors or joint controllers, including lawyers, auditors, and insurers.
   5. 5.1.5 HM Revenue & Customs, regulators, and other authorities.
   6. 5.1.6 ADDVantage Digital Solutions Ltd (our parent company) for corporate governance, legal compliance, and business administration.
   7. 5.1.7 Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
2. 5.2 We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
3. 5.3 Mandatory Disclosures and Exceptions to Confidentiality
   1. 5.3.1 Statutory and Legal Framework
   2. Notwithstanding our commitment to confidentiality and data protection, healthya ConX and healthcare providers using the platform may be legally required or professionally obligated to disclose personal data and Patient Health Information without consent in circumstances where disclosure is mandated by law, regulation, or overriding public interest.
   3. 5.3.2 Circumstances Requiring Mandatory Disclosures
      1. 5.3.2.1 Court Orders ad Legal Proceedings
         • Compliance with court orders, subpoenas, warrants, or legal proceedings
         • Production orders from regulatory authorities and law enforcement agencies
         • Criminal investigations where legally mandated under Police and Criminal Evidence Act 1984
         • 5.3.2.2 Safeguarding and Protection of Vulnerable Persons
         • Suspected child abuse or neglect under Children Act 1989 and Children Act 2004
         • Adult safeguarding concerns under Care Act 2014
         • Domestic violence, modern slavery, and serious harm prevention
         • Mental Capacity Act 2005 best interests’ determinations
      2. 5.3.2.3 Public Health Protection and Disease Control
         • Notifiable diseases under Health Protection (Notification) Regulations 2010
         • Infectious disease outbreak management and contact tracing
         • Food poisoning, contamination incidents, and public health emergencies
      3. 5.3.2.4 Professional Regulatory and Fitness to Practice
         • GPhC fitness to practice investigations
         • GMC serious professional misconduct cases
         • NMC professional standards investigations
         • Pharmacy inspections, compliance audits, and regulatory enforcement
      4. 5.3.2.5 NHS Fraud, Financial Crime and Security
         • NHS Counter Fraud Authority investigations
         • NHSBSA fraud detection and prevention
         • Prescription fraud, medicine diversion, and controlled drug offences
      5. 5.3.2.6 Patient Safety and Clinical Governance
         • Serious incidents requiring investigation under NHS England guidance
         • Never events and serious patient safety incidents
         • CQC regulatory inspections and investigations
         • Clinical negligence claims and patient harm cases
   4. 5.3.3 Public Interest and Emergency Disclosures
      1. 5.3.3.1 Overriding Public Interest
         • Prevention of serious crime, terrorism, or threats to national security
         • Protection of public safety, welfare, and essential infrastructure
         • Prevention of serious harm to vulnerable individuals
         • Maintenance of healthcare system integrity
      2. 5.3.3.2 Whistleblowing and Protected Disclosures
         • Patient safety concerns and clinical risks
         • Professional misconduct and regulatory breaches
         • Fraud, corruption, and serious financial irregularities
   5. 5.3.4 Professional Duty of Care
      1. 5.3.4.1 Clinical Best Interests
         • Information may be shared where it is in the patient's best clinical interests
         • Where the patient lacks capacity under Mental Capacity Act 2005
         • Where emergency treatment is required to save life or prevent serious harm
      2. 5.3.4.2 Duty to Warn
         • To prevent serious harm to the patient themselves
         • To protect identifiable third parties at immediate risk
         • To protect public health and community safety
   6. 5.3.5 Documentation and Accountability
      • All mandatory disclosures will be:
      • Fully documented with specific legal basis identified
      • Reviewed by appropriate clinical, legal, or designated personnel
      • Limited to the minimum information necessary
      • Subject to regular audit and governance processes
      • Where legally permitted, individuals will be informed of mandatory disclosures before or after disclosure, unless notification is prohibited by law.
   7. 5.3.6 Legal Framework Compliance
      • All mandatory disclosures comply with:
      • UK GDPR Article 6 (lawful bases) and Article 9 (special category data)
      • Data Protection Act 2018
      • Common Law Duty of Confidentiality exceptions
      • Human Rights Act 1998
      • Professional regulatory standards and codes of conduct
   8. 5.3.7 Future Legal and Regulatory Changes
      • This section covers current legal requirements as of the effective date. healthya ConX reserves the right to make mandatory disclosures as required by future legislation, regulatory changes, or emergency powers, conducted in accordance with applicable legal safeguards.

6. INTERNATIONAL TRANSFERS

1. Some of our external third parties are based outside of the UK so their processing of your personal data will involve a transfer of data outside the UK.
2. Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
   1. 6.1 We will only transfer your personal data to countries that have deemed to provide an adequate level of protection for personal data by the UK.
   2. 6.2 Where we use certain service providers, we may use specific contracts approved by the UK, which give personal data the same protection it has in the UK. Any international transfers of your data will be carried out in compliance with the UK GDPR and Data Protection Act 2018, including use of the Information Commissioner's Office's International Data Transfer Agreement and Addendum, in force 21st March 2022.
   3. 6.3 For US-based providers, we ensure participation in the Data Privacy Framework or equivalent certification.
   4. 6.4 We conduct Data Transfer Impact Assessments (DTIAs) where required.
   5. NHS patient data is subject to additional restrictions and may only be transferred internationally where specifically permitted by NHS England and with appropriate safeguards.
3. Please contact us at dpo@healthya.co.uk if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

7. DATA SECURITY

1. We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. These measures include:
   1. 7.1 ISO 27001-certified infrastructure
   2. 7.2 NHS Digital Data Security and Protection Toolkit (DSPT) compliance
   3. 7.3 Encryption of data at rest and in transit (TLS 1.3+)
   4. 7.4 Role-based access controls and multi-factor authentication
   5. 7.5 Regular penetration testing and vulnerability assessments
   6. 7.6 Staff training on data protection and cyber security
   7. 7.7 Incident response and breach notification procedures
   8. 7.8 Segregated networks for NHS data processing
   9. 7.9 Continuous security monitoring and threat detection
2. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
3. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. NHS data breaches are also reported to NHS Digital and relevant commissioning bodies.

8. DATA RETENTION

1. 8.1 How Long will you use my Personal Data for?
2. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
3. We retain personal data only as long as necessary for the purposes set out in this policy and in accordance with legal and NHS requirements. Retention periods include:
   1. 8.1.1 Clinical Records: 10 years for adults, 25 years for paediatric patients, or as required by the NHS Records Management Code of Practice
   2. 8.1.2 User Account Data: 7 years post-termination for HMRC and audit purposes
   3. 8.1.3 Consultation Review Logs: 12 months from resolution or closure
   4. 8.1.4 Financial and Transactional Data: 7 years for statutory accounting
   5. 8.1.5 Marketing Data: Until consent is withdrawn or 24 months after last interaction
   6. 8.1.6 Consent Records: 7 years from withdrawal or end of relationship
   7. 8.1.7 NHS Contract Management Data: As specified in NHS England guidance (typically 6 years)
   8. 8.1.8 Professional Registration Verification: Duration of contract plus 7 years
4. By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax and legal purposes. Details of retention periods for different aspects of your personal data are set out in the table in Section 4 above.
5. In some cases, we may 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.

9. YOUR LEGAL RIGHTS

1. Under certain circumstances, you have the following rights under data protection laws in relation to your personal data:
   1. a. Request access to your personal data
   2. b. Request correction of your personal data
   3. c. Request erasure of your personal data
   4. d. Object to processing of your personal data
   5. e. Request restriction of processing your personal data
   6. f. Request transfer of your personal data
   7. g. Right to withdraw consent
   8. 9.1 Special Considerations for NHS Data
      • Certain rights may be restricted where data is processed for NHS healthcare provision, regulatory compliance, or public health purposes. We will advise you of any restrictions when you make a request.
      • If you wish to exercise any of the rights set out above, please contact us at dpo@healthya.co.uk , setting out the details of your request.
   9. 9.2 No Fee Usually Required
      • You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
   10. 9.3 What we may need from you
       • We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it.
   11. 9.4 Time Limit to Respond
       • We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. CONSENT FRAMEWORK FOR NHS SERVICES

1. 10.1 Mandatory Service Consents
   1. As part of using healthya ConX services, patients and healthcare providers must provide specific consents. The platform captures and records the following consent categories:
   2. 10.1.1 Core Service Consent:
      • "Consent is required for the service provision and to share information about this consultation."
   3. 10.1.2 GP Practice Information Sharing
      • "Consent for the healthcare provider sharing information with the patient's GP practice."
   4. 10.1.3 NHS England and ICB Reporting
      • "Consent for the pharmacy sharing information with NHS England and ICBs (for reporting purposes)."
   5. 10.1.4 Third Party Presence in Consultation
      • "Consent to a third person other than patient & pharmacist being present in consultation room (if applicable)."
   6. 10.1.5 Community Pharmacy Referral
      • "Consent to forward referral to another community pharmacy (if applicable)."
   7. 10.1.6 Contract Management and Post-Payment Verification
      • "Consent for the pharmacy sharing information with NHSBSA and NHS England for the purpose of contract management and as part of post-payment verification (PPV)."
2. 10.2 Consent Management
   1. 10.2.1 All consents are captured electronically within the platform with full audit trails
   2. 10.2.2 Patients can withdraw specific consents at any time, though this may limit the services that can be provided
   3. 10.2.3 Healthcare providers are required to explain the implications of withholding consent before services commence
   4. 10.2.4 Consent records are maintained for the duration specified in Section 8

11. COOKIE POLICY

1. 11.1 Use of Cookies
   • healthya ConX uses cookies and similar technologies to ensure secure operation, enable essential features, and improve user experience.
2. 11.2 Types of Cookies11.2.1 Essential Cookies
   • SessionID: Maintains secure login state (expires at session end)
   • CSRF-Token: Protects against cross-site request forgery (expires after 24 hours)
   • AuthToken: Secure authentication token (expires after 8 hours
3. 11.2.2 Analytics Cookies
   • _ga (Google Analytics): Tracks anonymised user journeys (expires after 2 years)
   • _hjSession (Hotjar): Records anonymised UI interactions (expires after 30 minutes)
4. 11.2.3 Consultation Review Cookies
   • When a consultation is submitted for review, additional session cookies securely link the submitting clinician, reviewing clinician, and consultation data for audit purposes. These cookies do not contain patient-identifiable information and expire after review completion.
5. 11.2.4 NHS Integration Cookies
   • NHSSpineSession: Maintains NHS Spine connectivity (expires after 1 hour)
   • EPSToken: Electronic Prescription Service authentication (expires after 30 minutes)
6. 11.2.5 Consent Management Cookies
   • ConsentPrefs: Records consent choices (expires after 1 year)
   • CookieConsent: Cookie banner preferences (expires after 1 year)
7. 11.2.6 Marketing Cookies
   • Used only with explicit consent for newsletters or service updates.
8. 11.3 Managing Cookies
   • You can manage cookie preferences at any time via the platform's cookie consent manager or your browser settings. Disabling essential cookies may affect platform functionality and NHS integration capabilities.

12. YOUR LEGAL RIGHTS

1. 12.1 Lawful Basis
   • 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.
   • 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 or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
2. 12.2 Third PartiesExternal Third Parties:
   • Service providers acting as processors who provide IT and system administration services
   • Professional advisers acting as processors or joint controllers including lawyers, auditors and insurers
   • HM Revenue & Customs, regulators and other authorities
   • NHS bodies including NHS England, NHSBSA, ICBs, CQC, GPhC, GMC, NMC
   • Independent clinical reviewers and contracted healthcare professionals
3. 12.3 Healthcare Terms
   • PGD: Patient Group Direction, written instructions for medicine supply and administration
   • PSQ: Patient Suitability Questionnaire used in clinical assessments
   • EPS: Electronic Prescription Service, the NHS electronic prescribing system
   • e-RS: NHS e-Referral Service for booking appointments and managing referrals
   • DSPT: NHS Data Security and Protection Toolkit
   • ICB: Integrated Care Board, NHS statutory bodies responsible for healthcare commissioning
   • NHSBSA: NHS Business Services Authority, responsible for NHS payment systems
   • PPV: Post-Payment Verification, the process of auditing NHS service claims
4. 12.4 Your Legal Rights
   1. You have the right to:
      • Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
      • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected.
      • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it.
      • Object to processing of your personal data where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground.
      • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in certain scenarios.
      • Request transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format.
      • Withdraw consent at any time where we are relying on consent to process your personal data.

13. DISCLAIMER REGARDING LEGAL AND REGULATORY CHANGES

• This Privacy Policy is intended to comply with the UK GDPR, Data Protection Act 2018, NHS DSPT, and all current applicable UK laws and regulations. However, data protection, NHS, and healthcare regulations are subject to change. ADDVantage Digital Solutions Ltd and healthya ConX reserves the right to update this policy in response to new legislation, regulatory guidance, or operational requirements. Where changes materially affect your rights or our obligations, we will notify you as required by law.
• This policy may also be updated to reflect new purposes for processing, changes in our services, technological developments, or changes in applicable law. Material changes will be communicated to users via email and platform announcements. The current version will always be available at www.healthya.co.uk/privacy.

14. GLOSSARY

1. Accountability Principle:
2. The requirement for organisations to be responsible for, and able to demonstrate, compliance with the UK GDPR and DPA 2018.
3. Aggregated Data:
4. Statistical or demographic data derived from personal data but not considered personal data in law as it does not directly or indirectly reveal your identity.
5. Anonymisation:
6. Information that does not relate to an identified or identifiable individual and is not subject to the obligations of the UK GDPR6.
7. Appropriate Policy Document:
8. A document outlining compliance measures and retention policies for special category data, required for many substantial public interest conditions under the DPA 2018.
9. Consent:
10. A freely given, specific, informed and unambiguous indication of the data subject’s wishes by which they, by a statement or by clear affirmative action, signify agreement to the processing of personal data.
11. Controller:
12. The person or organisation who decides how and why to process personal data.
13. Data Processor:
14. A person or organisation who processes personal data on behalf of a controller.
15. Data Protection Impact Assessment (DPIA):
16. A process to help identify and minimise the data protection risks of a project, required for high-risk processing.
17. Data Subject:
18. The identified or identifiable living individual to whom personal data relates.
19. Data Sharing:
20. The disclosure of personal data by transmission, dissemination or otherwise making it available to another party.
21. DPA 2018:
22. The Data Protection Act 2018, which sits alongside the UK GDPR and sets out the framework for data protection in the UK.
23. Individual Rights:
24. The eight rights under UK GDPR: access, rectification, erasure, restriction, portability, objection, not to be subject to automated decision-making, and to be informed.
25. Lawful Basis:
26. The legal grounds for processing personal data under UK GDPR, including consent, contract, legal obligation, vital interests, public task, and legitimate interests.
27. Legitimate Interest:
28. The interest of an organisation in conducting and managing its business to enable it to give the best service/product and the best and most secure experience.
29. Personal Data:
30. Any information relating to an identified or identifiable natural person (‘data subject’).
31. Processing:
32. Any operation or set of operations performed on personal data, such as collection, storage, use, disclosure, or deletion.
33. Processor:
34. A person or organisation who processes personal data on behalf of a controller.
35. Profile Data:
36. Information about your interests, preferences, feedback, and survey responses.
37. Pseudonymisation:
38. Processing personal data in such a way that it can no longer be attributed to a specific data subject without the use of additional information, which is kept separately.
39. Special Category Data:
40. Personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, health data, or data concerning a person’s sex life or sexual orientation. This data needs greater protection.
41. Sub-processor:
42. A third party engaged by a processor to process personal data on behalf of the controller.
43. UK GDPR:
44. The UK version of the EU General Data Protection Regulation, as amended and incorporated into UK law from the end of the Brexit transition period.
45. Third Parties:
46. Organisations or individuals not part of healthya ConX or its group companies, including service providers, professional advisers, NHS bodies, and regulators.
47. Your Legal Rights:
48. Your rights under UK GDPR and DPA 2018, including the right to access, correct, erase, restrict, object, and transfer your personal data, and the right to withdraw consent.
49. This Privacy Policy is reviewed annually and as required by changes in law or processing activities.© 2025 ADDVantage Digital Solutions Ltd t/a healthya ConX. All rights reserved.