The purpose of this privacy notice is to tell you what information The MCL Group (Int) Limited trading as MCL Medics (“MCL Medics”) collects from you, how and when it may be collected and what happens to it. For the purpose of this Privacy Notice, “we” and “us” refer to MCL Medics.
Personal information is any personally identifiable information, such as your email address, name, home or work address, telephone number, bank details or tax codes, which can directly or indirectly identify you. We refer to it as “Personal information” here.
For the purpose of the applicable data protection laws including the General Data Protection Regulation, we, The MCL Group (Int) Limited, trading as MCL Medics, are the data controller of your personal data.
Unless an appropriate contract (as required by the General Data Protection Regulation) has been agreed and entered into by us and the relevant third party (for example your employer), MCL Medics will be a controller of your information as detailed in this Privacy Notice. Please contact us if you would like further information on this.
By continuing to use our portals, access our websites, completing our forms or by otherwise providing us with your information, you warrant that any data provided by you to us is accurate.
INFORMATION WE COLLECT FROM YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data from which an individual can no longer be identified (anonymous data).
Recording Voice Calls and Video Calls
To help improve efficiency and effectiveness of some of the services provided to you by phone or video call we may keep a record of the call.
We collect information about you:
- That you provide to us in person, including when you receive, or take part in, an assessment or treatment from us;
- When you complete our forms;
- From your employer;
- From other medical practitioners;
- That you provide to us online, including when you fill in forms on our site or portals; and
- That you provide when you contact us by phone, email or otherwise.
The type of information we collect from you is as follows:
- Personal contact details such as your name, title, postal address, telephone number, and personal email address;
- Date of birth, gender, marital status, dependants, next of kin and emergency contact information;
- Special categories of data, namely information about your health, including any medical condition, health and sickness records;
- Employment information such as your employee number, length of service and eligibility for workplace benefits;
- Technical information about your visits to our site and portals including but not limited to: your IP (Internet Protocol) address used to connect your device to the internet, traffic data, location data, log data, your browser settings, the date and time of your visits, and details regarding which pages you access. When you visit our site or portals our servers automatically record this type of information. For further information on this, please see our Cookies Policy: www.mcl-medics.com/cookies-policy/
- Demographic information such as postcode, preferences and interests.
USE OF YOUR INFORMATION
We will only use your personal data when and how the law allows us to. Most commonly, we will use your personal data
- We need it to perform the contract we are about to enter into or have entered into with you e.g. a contract to perform a medical;
- It is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests (further details of which are detailed below); and
- We need to comply with a legal or regulatory obligation.
With regard to processing information about your health, we will do so only where it is necessary for the purposes of preventative or occupational medicine, assessment of working capacity, medical diagnosis or provision of health care. Occasionally, we may seek your explicit consent to process information but we will be clear about requesting this from you when we do so.
When you provide us with your personal information in the context of receiving, or taking part in, an assessment or treatment from us, and completing the necessary forms, we are permitted to process your personal information (including health information) based on the lawful grounds detailed above. However, depending on the nature of the assessment or treatment, we may ask whether you are comfortable with us sharing certain personal information (including health information) with third parties, namely your employer or contracting company. Whilst we have a lawful basis for sharing the personal information (including health information) in accordance with data protection legislation and grounds noted above, we will not share the information if you express a wish for us not to do so. We will continue to hold your data for the purposes contained in this notice (in accordance with our data retention procedures detailed below) and if you change
your mind about sharing the information, you can simply contact us and we will assist with providing the information.
Please contact us if you need details about the specific legal grounds we are relying on to process your personal data.
How We Use Your Information
We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:
- To assess your fitness to work and identify alterations that should be made to your working environment;
- To carry out, or assist others to carry out, medical diagnosis and provide health care treatment;
- To arrange onshore accommodation where required;
- To carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
- To analyse the information we collect from you in order that we can examine trends and patterns in the information and improve our site and portals;
- To ensure that content from our site and portals is presented in the most effective manner for you and your device;
- To notify you about changes to our service;
- To allow you to participate in the interactive features of our site and portals, when you choose to do so;
- To measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you; to make suggestions and recommendations to you and others users of our site and portals about goods or services that may interest you or them;
- To provide you, or permit selected third parties to provide you, with information to contact you in order to send you details of our products and services which may be of interest to you;
- For our internal record keeping;
- To appropriately deal with any complaints or issues with our services, site or portals; and
- For all other purposes consistent with the proper performance of our operations and business.
We do not process personal data through automated decision making processes.
It is your choice whether you receive information such as marketing from us. If you indicated that you are interested in receiving regular information about our activities, we may send you communications electronically or by post. We will not contact you for marketing purposes unless you have given your prior consent. If, at any time, you no longer wish to receive this information, please send a written request to firstname.lastname@example.org.
Also, all of our email marketing correspondence gives you the option to opt-out of receiving further marketing emails. Please note that you will still receive emails directly related to an enquiry you raised with us.
WHERE WE STORE YOUR INFORMATION
All information you provide to us is stored on secure servers inside the European Economic Area (“EEA”).
Due to the global nature of our services, the information that we collect from you may be accessed, via our servers, from outside of the EEA. Whenever we make your personal data available outside the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We may make your personal data available in countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
- Where we use providers based in the US, we may allow them to access data if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
Please contact us if you want further information on the specific mechanism used by us when making your personal data available outside the EEA.
DISCLOSURE OF YOUR INFORMATION
The information you provide to us will be treated as confidential. However, we may disclose your information to other third parties who act for us for the purposes set out in the notice or for purposes approved by you.
We may disclose your personal information to third parties, including:
- Appropriate healthcare providers and professionals;
- State bodies such as the Health and Safety Executive and the Maritime and Coastguard Agency;
- Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006; analytics, search engine and service providers that assist us in the improvement and optimisation of our site and portals;
- Your employer or contracting company subject at all times to your wishes (please see above for further information);
- If we are under a duty to disclose or share your personal data in order to comply with any legal obligation or contract;
- To protect our rights and property, or our safety and our users’ safety;
- For the purposes of preventing or reporting any illegal or immoral activity; and/or
- For the purposes of appropriately dealing with any complaints or issues with our site or the portals.
We require all third parties to respect the security of your personal data and to treat it in accordance with applicable data protection legislation. 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.
Under applicable data protection legislation, you have the right under certain circumstances to:
- Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check we are lawfully processing it;
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected;
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see
- Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party). You also have the right to object where we are processing your personal information for direct marketing purposes;
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it;
- Request the transfer of your personal information to another party; and
- Withdraw your consent to the processing of your personal information at any time. If you would like to exercise any of your rights above, please contact us at Compliance@mcl-medics.com. You also have the right to complain to the Information Commissioner’s Office in relation to our use of your information.
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
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.
In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site or portals. Any transmission is at your own risk. 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.
Your data may be stored by third parties on our behalf. We, and our third party contractors, employ security measures to protect your information from access by unauthorised persons and against unlawful processing, accidental loss, destruction or damage.
Links to other websites
Our site and portals contains links to other websites of interest. If you use these links, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information you provide whilst visiting such sites and such sites are not governed by this Notice. You should exercise caution and check the terms and conditions and privacy notices which apply to third party websites.
CHANGES TO YOUR INFORMATION
Please help us keep our records updated by informing us of any changes to your information.
CHANGES TO OUR PRIVACY NOTICE
We may amend this notice from time to time. If we make any substantial changes, including changes to the purposes for which we use your personal information, we will notify you by posting a prominent notice on our site and portals and, where appropriate, notify you by email.
If you have any queries concerning your personal information or any questions on our use of the information then please contact us at Compliance@mcl-medics.com
Date of last change 11.07.18