iPLATO Healthcare Ltd (“we”, “us”, “our”, ”iPLATO“), is a company registered in England & Wales with company number 6131747 with registered offices at 13th floor, Millbank Tower, 21-24 Millbank, London SW1P 4QP.
We provide the myGP® mobile application and are committed to protecting and respecting your privacy. We act as both a data controller and a data processor under UK law. We are the data controller for myGP® App registration data, for anything you enter directly into certain areas of myGP® (eg: medication reminders, self-care tracking data), and for data we process with your explicit consent. This means we are responsible for determining the purposes for which and the manner in which this personal data is processed. However, for other features (eg: messaging / appointment bookings / repeat prescriptions / etc) we provide these services on behalf of your GP practice / healthcare providers. In these cases, we are simply processing your personal information on their instruction. These parties are data controllers in their own right and have their own privacy policies.
Please note that if you access our service using your NHS login details, the identity verification services are managed by NHS England. NHS England is the controller for any personal information you provided to NHS England to get an NHS login account and verify your identity, and uses that personal information solely for that single purpose. For this personal information, our role is a “processor” only and we must act under the instructions provided by NHS England (as the “controller”) when verifying your identity. To see NHS login’s Privacy Notice and Terms and Conditions, please click here. This restriction does not apply to the personal information you provide to us separately.
This policy applies to your use of the myGP® mobile application software (App) once you have downloaded the App onto your mobile or handheld device. This policy also applies to any of the services accessible through the App (Services).
This policy sets out the basis on which any personal information we collect from you, or that you provide to us, or that is provided to us by your GP / healthcare services / NHS central services, will be processed by us. Please read this policy carefully to understand how we will treat your personal information.
This is information you give us about you when filling in forms/screens on the myGP® App or registering for Services through myGP®, through any interactions you undertake or services you request or source through myGP® and via any health or monitoring device you connect to myGP®, when uploading your image, or when corresponding with us by phone, e-mail or otherwise. It will be clear at the time what personal information we are requesting from you. If you do not provide the personal information necessary or withdraw your consent for the processing of your personal information, where this information is necessary for us to provide myGP® services to you, we will not be able to provide these services to you. You don’t have to provide data and can simply choose to stop using the App at any time.
Each time you use myGP® we automatically collect the following information:
Where you enable use of your device camera or audio or choose to upload files or images stored on your device, these are used for the purpose explicitly stated in the App at the time when you enable these services. If you choose not to enable these services you cannot make use of the video / audio call or file sharing functionality
Additionally, if you choose to enable location services on your device when onboarding, location data from your device will be used to make it easier for you to search for your GP practice within the app. If you choose not to share your location, you are able to enter your GP / address manually.
We may receive information about you from your GP / healthcare provider to facilitate provision of relevant Services. This may include your name, NHS number and relevant contact details as well as sensitive information, for example prescription and appointment information. They are the controller of this data and we are a contracted processor; they provide us with such data to enable us to provide the services they specify to you.
We DO NOT use your data for marketing purposes unless we ask for your explicit consent.
Any personal information you submit through myGP® or that is accessed by myGP® is generally required for providing the Services to you.
Where we receive information from your GP / healthcare provider we rely on their legal basis for processing this information.
However, we may rely on other lawful bases for using your personal information. Specifically, we use information held about you in the following ways:
2. Where we have a legal obligation
To make disclosures as required by or in compliance with reasonable requests by regulatory bodies including the General Medical Council or Care Quality Commission, or as otherwise required by law or regulation.
Please note, the alternative or additional services, generated when you enter the information requested for booking an appointment in the App, are specified by your GP or healthcare provider. This service is only available where your GP or healthcare provider has requested it.
Where we rely on legitimate interest as a ground for processing your personal information, before we go ahead, we carry out a ‘balancing test’ to ensure that our processing is necessary and that your fundamental rights of privacy are not outweighed by our legitimate interests. We keep a record of these balancing tests and you can request to see the information they contain. You can find out more by contacting us using the details below.
Where any of the personal information we use contains Sensitive Information, and in addition to the above, where this data is received from your GP / healthcare provider, we rely on their lawful basis to use such data for healthcare purposes. This includes providing medical record access, and specifically access to Covid vaccination data, on behalf of your GP.
We will not sell your personal information or share it for marketing purposes.
We may disclose your personal information:
We will store your personal information at our secure data centre which is located within the United Kingdom. We do not transfer your personal information outside the UK. All data will be encrypted when being transferred to and from your device to myGP® or to our data centre. It is your responsibility to keep any passwords or pin codes used to access myGP® confidential.
If you choose to enable access to your medical record through myGP®, please note that we do not store this content, we simply make the information held by your GP available to you on your device.
If you choose to conduct a video consultation with your healthcare provider through myGP® then please be assured that at no time do we record or store the video or audio footage in any form.
We take all steps reasonably necessary to ensure that your data is treated securely through strict procedures and security features to prevent unauthorised access to your personal information. However, we cannot guarantee the secure transmission of information via the internet due to security threats outside our control and as such, any transmission of information is at your own risk.
We will retain your personal information for as long as needed to fulfil the purposes outlined in the ‘How does myGP® use your personal information?’ section above or for a period specifically required by applicable regulations or laws. For example, we generally keep your personal information for as long as you remain a registered user of the App.
When determining the relevant retention periods, we will take into account factors including:
Otherwise, when requested, we securely erase or anonymise your personal information where you cease to be a user of the App and we no longer require your information for the purposes collected.
myGP® or any other Service we offer may contain links to other independent third-party websites or mobile applications (“Third-party Sites”).
These Third-party Sites are not under our control, and we are not responsible for and do not endorse their content or their privacy policies (if any). You will need to make your own independent judgement regarding your interaction with any Third-party Sites, including the purchase and use of any products or services accessible through them.
myGP® uses the following third party trackers so we can provide effective and responsive services to our users:
Google Firebase / Fabric (ios only) – provides metrics on successful sign-ins, screen views and button hits. We use this to assess App usage levels.
Elastic – provides information on screen views, button hits, backend events and what is being entered in the app. We use this to assess feature performance and investigate and address issues.
By law, you have a number of rights (subject to certain conditions) when it comes to your information. Further information and advice about your rights can be obtained from the Information Commissioners Office (ICO). You can exercise any of these rights by contacting us using our details below.
Rights |
What does this mean? |
The right to object to processing |
You have the right to object to certain types of processing, including processing where we rely on our legitimate interest as a ground for processing. |
The right to be informed |
You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights. This is why we’re providing you with the information in this Privacy Policy. |
The right of access |
You have the right to obtain access to your information (if we’re processing it), and certain other information (similar to that provided in this Privacy Policy). This is so you’re aware and can check that we’re using your information in accordance with data protection law. |
The right to rectification |
You are entitled to have your information corrected if it is inaccurate or incomplete. |
The right to erasure |
This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your information where there is no compelling reason for us to keep using it. This is not a general right to erasure, there are exceptions. |
The right to restrict processing |
You have rights to ‘block’ or suppress further use of your information in certain circumstances. When processing is restricted, we can still store your information, but may not use it further. We keep lists of people who have asked for further use of their information to be ‘blocked’ to make sure the restriction is respected in future. |
The right to data portability |
You have rights to obtain and reuse your information for your own purposes across different services. For example, if you decide to switch to a new provider, this enables you to move, copy or transfer your information easily between our IT systems and theirs safely and securely, without affecting its usability. |
The right to lodge a complaint |
You have the right to lodge a complaint about the way we handle or process your information with your national data protection regulator. See details of the UK data protection regulator in the contact us section below. |
The right to withdraw consent |
If you have given your consent to anything we do with your information, you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your information with your consent up to that point is unlawful). Note that such withdrawal in certain circumstance may mean we can no longer continue to provide the Services to you. |
We usually act on requests and provide information free of charge, but may charge a reasonable fee to cover our administrative costs for:
Alternatively, we may be entitled to refuse to act on the request.
Please consider your request responsibly before submitting it. We will generally respond within one month from when we receive your request but, if the request will take longer to deal with, we will come back to you and let you know.
We update our privacy policy from time to time and any changes we may make to our privacy policy in the future will be posted online and, where appropriate, notified to you through the App. The new terms may be displayed on-screen and you may be required to read and accept them to continue your use of myGP®.
If you have any questions, comments or requests regarding this Policy, please get in touch with us:
iPLATO Healthcare Ltd
13th floor, Millbank Tower, 21-24 Millbank, London SW1P 4QP
info@iplato.com
You can contact our Data Protection Officer by emailing: ig@iplato.com
If you are not satisfied with our response, or you think we are not complying with data protection law, you can make a complaint to the UK data protection regulator – the Information Commissioner:
Address: |
Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF |
Phone: |
0303 123 1113 |
Email: |
casework@ico.org.uk |
Website: |
ico.org.uk/concerns/ |
