Privacy Policy
Introduction
We are Galenic Laboratories Limited, trading as Roseway Labs (referred to in this privacy policy as “we”, “us”, “our”, “Roseway Labs”). We are a provider of pharmacy services to private prescribers who are registered to prescribe in the UK. We are the data controller and responsible for your personal data.
You are confirming that you agree to the terms of our privacy policy when you use our services or our websites. Please contact us at info@rosewaylabs.com if you have any questions.
Contact Details
If you have any questions about this privacy policy or our privacy practices, please contact us. Roseway Labs operates from Zetland House, 5-25 Scrutton Street, London EC2A 4HJ. We can be contacted on 03330 504030 or info@rosewaylabs.com.
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator 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.
Patient Data
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).
We may collect, use, store and transfer different kinds of personal data about patients and prescribers as part of our pharmacy services.
Personal information, relating to a patient, is passed to us by a prescriber in order to fulfil a prescription or a retail order. This data may include name, address, contact details, date of birth, any relevant medical history in relation to allergies you may have to any medication or ingredients, and the medication and/or items ordered by the prescriber.
Processing patient data
We will only use personal data when the law allows us to. We use personal information to provide our products and services. Most commonly, we will use patient personal data order to dispense prescriptions in the following circumstances:
a. Legal obligation: where we are under a legal obligation to collect and process personal data. For example, under the Human Medicines Regulations 2012, Roseway Labs, as a dispenser of private prescriptions, is required to maintain patient medical records. It is an offence under these regulations to breach this legal obligation.
b. Legitimate interests of Roseway Labs: where we have a legitimate business interest in collecting and processing personal data. For example, in managing our business to give prescribers and patients the best services and medications and the best and most secure online 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). Roseway Labs has a legitimate interest in processing patient personal data to provide patient care and maintaining accurate patient records is consistent with good patient care.
c. Contract with the data subject: means processing data where it is necessary for the performance of a contract to which the data subject is a party or to take steps at their request before entering into such a contract. For example, where patients send us their prescriptions directly for us to dispense, they will be entering into a contract with us.
d. Consent: we can only rely on consent where consent has been clearly obtained from the data subject, either by the prescriber which is then communicated to us, or directly to us. Generally, we do not rely on consent as a legal basis for processing personal data although we will get consent before sending third party direct marketing communications via email or text message. Patients have the right to withdraw consent to marketing at any time by contacting us.
Medical and health information is classified as ‘special category personal data’ and we are required to process this special category data with a higher level of care than for ordinary personal data. We process medical and health information in order to provide healthcare treatment and to fulfil a contract with the prescriber to deliver the requested medication or products. Our pharmacists, or a technician working under their supervision, are responsible for the processing of this personal data in order to provide the requested treatment.
Purposes for which we will use patient data
We use a patient’s data to provide the goods and services requested by a prescriber, or by the patient directly. This includes fulfilling the prescription and order, taking payments, arranging delivery and providing information updates in relation to the order.
Where a prescriber deems it necessary to pass us relevant medical history, it is to inform our pharmacists about relevant conditions or medicines that a patient may already be taking, which could have an impact on, or interaction with, any prescribed medication. Equally, we may pass information to a prescriber about any adverse reaction or sensitivity to certain ingredients that a patient may have told us about. These exchanges are made with the purpose of safeguarding health and improving the personalisation of the medication.
We will only use 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.
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.
Retention of patient data
We will only retain personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
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 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, regulatory, tax, accounting or other requirements.
We retain records of patient data on our systems, which are protected by password access and securely hosted on cloud-based servers within the EU.
Under the Human Medicine Regulations 2012, we have a legal duty to retain records for either two or five years, depending on which medication was prescribed, and in some cases, for longer. Retention periods begin when the record ceases to be operational. We automatically archive electronic records that have not been used for a period of 5 years.
Sharing personal data and patient data
We may share personal data with the parties set out below for the purposes set out above:
- External Third Parties such as:
- Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. 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 policy.
Patient data will not be shared with other organisations unless it is necessary for the provision of our or related services, such as delivering the order or where there is a legal requirement to do so. In these situations, we provide only that information which is essential to deliver the service or comply with the law.
Roseway Labs will not sell the data that it holds to anyone, for any reason. Any third party organisation with access to patient data is not allowed to use it for their own commercial purposes and they are only permitted to process patient data for specified purposes and in accordance with our instructions.
A patient or prescriber should never be contacted by one of our third party suppliers for marketing purposes or any purpose other than that related to the service they are providing for Roseway Labs, unless they have chosen to subscribe to receive updates from us. If contact is made for a reason other than delivering the designated service or receiving updates for which they signed up, the recipient should inform Roseway Labs as soon as is practicable and action will be taken.
International transfers
Some of our external third parties are based outside the UK so their processing of personal data will involve a transfer of data outside the UK. 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:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data; and/or
- Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.
Security
We take the responsibility of looking after patient data, seriously. We operate in a secure office, within a secure building. Our operating procedures are designed to protect the data we hold and we have appropriate security measures in place to protect our physical and electronic systems from unauthorised access or use, and to prevent personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to 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.
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.
Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These rights are:
· 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, though we may need to verify the accuracy of the new data you provide to us.
· 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. 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.
· Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
· Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: