About Esplanade Healthcare Ltd
Esplanade Healthcare Limited provides occupational health services including:

• Occupational Health Medicals
• Management reports
• Drug & alcohol screening
• Pre-employment medicals

 Our Registered Office is at 1 The Esplanade, Rochester, Kent ME1 1QE

Who is the Policy for?
This policy is information for people that we hold information for or are about to hold their information. This includes our clients employees but we also provide private occupational health medicals in this case we hold data for you the individual.
Esplanade Healthcare Ltd is committed to ensuring we hold your data securely this policy explains:

• What we hold?
• Why we hold it?
• How long we hold it for?

Esplanade Healthcare Ltd holds “Personal and Special Information” as defined by the GDPR and Data Protection Regulations. We treat our responsibilities very seriously as an organisation and as individuals we will always treat your information as important and ensure that we protect its use, access and accuracy.

Esplanade Healthcare Ltd is registered with the Information Commissioners Office Registration Number:  Z1707454

How to contact us
If you have any questions about our Privacy Policy or the information we collect or use about you, please contact;

The  Data Protection Officer
1 The Esplanade
Rochester
Kent ME1 1QE

Why do we hold your data?
Esplanade Healthcare Ltd employs specialist clinicians who provides advice and medical treatment. These include a doctor and specialist occupational health nurse.

In some instances we may hold your employer’s occupational health records; these are medical and personal records that must be held for your safety and wellbeing at work. Authorised medical professionals may only hold occupational health records as set out in the Access to Health Records Act (1990)

.
We process your data for this purpose in compliance with:
GDPR Article 9 (2)(h)    ‘processing is necessary for the purposes of preventive or occupational medicine, for the assessment of the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services on the basis of Union or Member State law or pursuant to contract with a health professional and subject to the conditions and safeguards referred to in paragraph 3;”

GDPR Article 6 (1)(f)     ‘processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests of fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the subject is a child;’

For the provision of occupational health services we hold information about our client’s employees. This includes personal details e.g. Name, Home address, Date of Birth, Job details and medical records. We need this information to be able to provide accurate advice to you and your employer ensuring that work does not damage your health and you are fit for the work you do.

The personal data we collect will be adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed.

Esplanade Healthcare Ltd also holds information for purposes of the delivery of general medical services.

• We need personal information e.g. name address, date of birth in order to identify and verify the correct person and in some cases where we need to communicate with your health care provider this is the standard identification information used with the NHS.
• We need your personal contact details e.g. telephone and email to assist us communicating with you when booking appointments.
• We need and will create medically confidential information so that our clinicians can provide professional advice based on your health fitness and wellbeing.

How we protect your information
We take information and system security very seriously and we strive to comply with our obligations at all times.

All medical information is held securely and only accessed by our employees. Occupational health reports and medical records are kept in a secure filing system.

Some of the information we hold is electronic and we do hold paper records in a secure environment. Our computer servers are located in England and your information is not stored or held outside the UK.

We operate a secure IT system providing a controlled environment that effectively manages risks to the confidentiality, integrity and availability of your information.

Who we may share your information with
Law enforcement, for the prevention and detection of crime.

Health and Safety Executive
Our regulators and supervisory authority e.g. the Information Commissioner’s Office for the UK
Your employer but we will always obtain your consent before we provide information.

X    We do not and will never sell your information to anyone else.
X    We will not use your information to sell you anything or promote any services that are not related to the provision of occupational health or healthcare services.

Medical Reports
Our clinicians may require medical reports from your healthcare professionals e.g. GP or specialist Consultant; if required Esplanade Healthcare Ltd will always obtain your written consent before obtaining the report. Before you give your consent to allow Esplanade Healthcare Ltd to obtain any report you will be advised of:

• The reason why the report is needed.
• Your rights under the Access to Medical Reports Act (1988)
• Your right to see a copy of the report being sent to Esplanade Healthcare Ltd if you wish
• That Esplanade Healthcare Ltd will send a report to your employer based on the medical report sent to us. It will not be the actual report that your healthcare provider sends to us.
• How you can see the report that Esplanade Healthcare Ltd sends to your employer
• How you can ask for inaccuracies to be corrected, or for additional information to be added.

Where Esplanade Healthcare Ltd sends a report to your employer, if the report is being written by an Occupational Health Physician (Doctor) you will have the opportunity to see the report before it is sent to your employer. Reports are only sent to employees via our secure email procedures. If the report being sent to your employer is written by an Occupational Health Advisor (Nurse) you can obtain a copy of the report from your manager.

Data Retention
When your employer becomes a client of Esplanade Healthcare Ltd the historical occupational health records held by the previous occupational health provider are transferred to us. You will have been consulted on this transfer and have the right to object to the transfer. Objecting to the transfer may affect your health and wellbeing at work placing you at a disadvantage.

During the time that Esplanade Healthcare Ltd provides your occupational health service we will create and add our records to your occupational health file. If your employer leaves Esplanade Healthcare Ltd your occupational health file will be transferred to your new occupational health provider and you should be consulted on that change at that time. Esplanade Healthcare Ltd will not retain a copy of your records after your employer leaves us.

Unless we have copied your occupational health records we will not destroy any original documents. We hold your occupational health records on behalf of your employer and will store information in line with their data retention policy. You may wish to contact your employer to confirm their actual data retention policy. Your occupational health records will be kept whilst you are employed by your employer. After you leave their employment there are certain legal time scales that your employer needs to retain your records for.

 In all other cases Esplanade Healthcare Ltd Retention Policy is:

Reason to retain records | Time Period

Health Surveillance(Industrial Disease) Records | Asbestos 40 yrs Ionising 30 yrs

OH Records | 75th birthday or 6 years after employment whichever is the sooner

Legal Information
The UK Data Protection Regulations are specific about the treatment of personal and special data, you have the right to receive a copy of your records by making a Subject Access Request in writing. To request a copy of your Data Please submit your request to Dr James Redman, Esplanade Healthcare Ltd, 1 The Esplanade, Rochester, Kent ME1 1QE

Right to Rectify – you have the right to have the personal data we hold about you corrected if it is factually inaccurate. This right does not extend to matters of opinion, such as assessments of performance or fitness to work.

Right to Erasure – in some limited circumstances, you have the right to have personal date we hold about you erased (the ‘right to be forgotten’). This right is not generally available where we still have a valid legal reason to keep the data (for example, because we are obliged to do so by law)
Esplanade Healthcare Ltd will only use qualified clinicians when we provide advice or services to you or your employer our clinicians are regulated and authorised by, Nursing Midwifery Council, General Medical Council, and Faculty of Occupational Medicine of the Royal College of Physicians.

How to make a complaint
We will always strive to collect, use and safeguard your personal information in line with data protection laws. If you do not believe we have handled your information as set out in our Privacy Policy, please contact our clinic and speak to a member of staff and we will do our utmost to make things right.

If you are still unhappy, you can complain to the Information Commissioners Office.
Their contact details are:

ICO
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
www.ico.org.uk

Dr James Houston Redman MRCGP AFOM DMJ
Director
Esplanade Healthcare Ltd
Policy Review Date 01/07/2024
Review Date :  01/07/2025