Privacy Notice

Indigo Medical, referred to as 'we' or 'our' is committed to protecting the privacy and security of your personal information.

This Privacy Notice describes how we collect and use personal information about you during and after your relationship with us and we will only use information collected lawfully in accordance with: –

• Data Protection (Jersey) Law 2018 (“DPJL”)
• The General Data Protection Regulations Legislation (“GDPR”)
• Human Rights (Jersey) Law 2000
• Common Law Duty of Confidentiality
• NHS Codes of Confidentiality and Information Security, or Jersey equivalent

Indigo Medical is a "Data Controller", which means we are responsible for deciding how we hold and use personal information. We are also a “Data Processor” when we collect and process data on behalf of another data controller, for example, the Government of Jersey.

Indigo Medical is registered with the Jersey Office of the Information Commissioner (“JOIC”) – Registration No 68565.

We will comply with data protection law, the principles of which says that the personal information we hold about you must be: -

1. Used lawfully, fairly and in a transparent way.
2. Collected only for valid purposes that we have clearly explained to you and not used in any way incompatible with those purposes.
3. Relevant to the purposes we have told you about and limited only to those purposes.
4. Accurate and kept up to date.
5. Kept your data only as long as necessary for the purposes we collected it.
6. Kept securely.

We will also only transfer your information when it is safe to do so, when necessary, and your information is protected in the same way that we protect it.

Indigo Medical is accountable to you and the Authorities to show compliance with the data protection laws and demonstrate how we are compliant.

The Data Protection Officer ("DPO")

We have appointed a DPO to oversee compliance with this Privacy Notice and all other data processing activities within the practice.

If you have any questions about this Privacy Notice or how we handle your personal information, contact the DPO at indigomedical@indigo.gpnet.je.

You have the right to make a complaint at any time to the JOIC.

Contact details for these are outlined at the bottom of this Privacy Notice.

• The Kind of Information We Hold About You

Personal data, or personal information, means any information about an individual from which that person can be identified, directly or indirectly. It does not include data where the identifying information has been removed (anonymous data).

To explain this to you, we will list our different services when we collect or use additional information about you.

How Is Your Personal Information Collected?

We collect personal information about you when you contact us, visit or surgeries, see one of our GP’s or provide use with your data for another specific purpose.

What information do we collect about you when you register with us?

• Name
• Title
• Address
• Data of Birth
• Identification documents
• Telephone number
• Occupation
• Email address
• Signature
• Marital status

Where necessary, we may also collect the following information:

• Country of Birth
• Nationality
• Country of Residence
• Current Gender
• Residential Status
• Preferred name
• Previous name
• Birth Gender

What Special Category Data do we collect about you?

When we collect Special Category data, we will always have a clear legal basis to process this or your explicit consent. If we rely on your explicit consent, you can withdraw this at any time by contacting our DPO at indigomedical@indigo.gpnet.je.

Special Category data is any information relating to your health, gender, race, sexual orientation, sex life, genetic or biometric data etc.

An example of this processing would be the medical record we keep on all our patients containing their health conditions, history, and examination reports. We have a legal obligation to collect this information and to store it.

How We Will Use Information About You?

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:

Processing Activity	Legal Basis for Processing Personal Data	Condition for Processing Special Category Data
General administration of Practice Telephone messages left for GP’s Invoicing for visits Providing prescriptions for medication	Article 9 Schedule 2, Part 1(1) Consent Article 9 Schedule 2, Part 1 (4) Public Function Article 9 Schedule 2, Part 1 (5) Legitimate Interest	Article 9 Schedule 2, Part 2(6) Consent Article 9 Schedule 2, Part 2(13) Public Function Article 9 Schedule 2, Part 2(15) Medical Purposes
Registration as a new patient Transfer of patient records form another GP Surgery Consultation with GP Transfer of patient records to another GP Surgery	Article 9 Schedule 2, Part 1(1) Consent Article 9 Schedule 2, Part 1(2) Contract Article 9 Schedule 2, Part 1(4) Public Function	Article 9 Schedule 2, Part 2(6) Consent Article 9 Schedule 2, Part 2(2) Other Legal Obligation Article 9 Schedule 2, Part 2(13) Public Function Article 9 Schedule 2, Part 2(15) Medical Purposes
Medical notes held on patient Referral letters sent to Hospital, Specialists, etc. Requests for medical examinations, Blood reports, x-rays, MRI scan etc.	Article 9 Schedule 2, Part 1(1) Consent Article 9 Schedule 2, Part 1(2) Contract Article 9 Schedule 2, Part 1(4) Public Function	Article 9 Schedule 2, Part 2(6) Consent Article 9 Schedule 2, Part 2(2) Other Legal Obligation Article 9 Schedule 2, Part 2(13) Public Function Article 9 Schedule 2, Part 2(15) Medical Purposes
Medication lists Medication reviews Health Risk Screening / Risk Stratification	Article 9 Schedule 2, Part 1(1) Consent Article 9 Schedule 2, Part 1(2) Contract Article 9 Schedule 2, Part 1(4) Public Function	Article 9 Schedule 2, Part 2(13) Public Function Article 9 Schedule 2, Part 2(15) Medical Purposes
Safeguarding and other legal requirements Complying with a lawful request for disclosure Complying with a data subject’s rights	Article 9 Schedule 2, Part 1(1) Consent Article 9 Schedule 2, Part 1(2) Contract Article 9 Schedule 2, Part 1(3) Vital Interest Article 9 Schedule 2, Part 1(4) Public Function	Article 9 Schedule 2, Part 2(6) Consent Article 9 Schedule 2, Part 2(13) Public Function Article 9 Schedule 2, Part 2(15) Medical Purposes Article 9 Schedule 2, Part 2(22) Counselling

Change of purpose

We will only use your personal information for the purposes 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 we need to use your personal information for an unrelated purpose, we will notify you and explain the legal basis that allows us to do so.

Data Sharing

We may, on occasions, pass your Personal Information to an organisation outside of Indigo Medical exclusively to process on our behalf; these organisations are called Data Processors.

We require these parties to agree to process this information based on our instructions and requirements consistent with this Privacy Notice.

We do not pass on information gained from your engagement with us without a clear legal basis for doing so.

Our regular partner agencies that we share information with are.

• Accident and Emergency Department, General Hospital
• Other GP’s, on call and out of hours service
• Independent Professionals such as dentists, opticians, pharmacists
• Ambulance Service
• Social Care Services
• Fire and Rescue Services
• Police & Judicial Services
• Other ‘data processors’ which you will be informed of

Your information will only be shared if it is appropriate for the provision of your care or required to satisfy our statutory function and legal obligations.

The personal data we collect from you may be transferred to and stored at a destination outside the European Economic Area ("EEA").

It may also be processed by companies outside the EEA who work for one of our service providers or us.

If we do this, we ensure that your privacy rights are respected in line with this notice and the same protection is given to your personal information as laid down by the DPJL and GDPR.

How do we maintain the confidentiality of your records?

We are committed to protecting your privacy and will only use information that has been collected lawfully. We adhere to DPJL and GDPR, the NHS Codes of Confidentiality and Security, as well as guidance issued by JOIC.

Every member of staff who works for Indigo Medical has a legal obligation to keep information about you confidential. We maintain our duty of confidentiality by conducting annual training and awareness, ensuring access to personal data is limited to the appropriate staff and information is only shared with organisations and individuals that have a legitimate and legal basis for access.

Data Security

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, altered or disclosed, or accessed in an unauthorised way. In addition, we limit access to your personal information to those Colleagues, Agents, Contractors and other third parties on a need to know basis.

They will only process your personal information on our strict instructions, and they are subject to a duty of confidentiality.

Details of these measures may be obtained from our Data Protection Officer (DPO).

We have put in place procedures to deal with any suspected data security breach and notify you and the JOIC of a suspected breach where we are legally required to do so.

Data Retention

All data is retained securely and only used for the purposes set out in the Law. Data is retained to comply with our statutory obligations and in accordance with our retention schedule. If you would like a copy of our retention schedule, please contact our DPO at

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 data. The purposes for which we process your data and whether we can achieve those purposes through other means and the applicable legal requirements.

You can request our Data Retention Schedule from our DPO if required.

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 for research purposes.

Rights of Access, Correction, Erasure, and Restriction

The personal information we hold about you must be accurate and current. Please keep us informed if your information changes during your relationship with us.

Under certain circumstances, by law, you have the right to:

• Request access to your personal information (commonly known as a "data subject access request"). This right enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
• Request correction of the personal information that we hold about you. This right enables you to have any incomplete or inaccurate data we hold about you corrected.
• Request erasure of your personal information. This right enables you to ask us to delete or remove personal data where there is no good reason for us to continue 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 below).
• Object to processing your personal information where we rely on a legitimate interest (or those of a third party). There is something about your particular situation that makes you want to object to processing on this ground. You also have the right to object to processing your personal information for direct marketing purposes.
• Request the restriction of processing of your personal information. This right 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.

If you want to review, verify, correct or request the erasure of your personal information, object to the processing or request that we transfer a copy of your personal information to another party, contact our DPO at indigomedical@indigo.gpnet.je.

You will not have to pay a fee to access your personal information (or exercise any other rights). However, we may charge a reasonable fee if your access request is unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

How to request your information and what we may need from you

Use the Data Subject Access Request form, available on our Cookie Banner. If you have any questions about this process or any of your rights, contact our DPO at indigomedical@indigo.gpnet.je

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or exercise any of your other rights).

We will respond to your request within FOUR WEEKS after and upon satisfactory verification of your identity.

Right to Withdraw Consent

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time.

To withdraw your consent, contact our DPO at indigomedical@indigo.gpnet.je.

Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to unless we have another legitimate basis for doing so in law.

Changes to this Privacy Notice

We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates.

We may also notify you in other ways from time to time about the processing of your personal information or requesting you to confirm the accuracy of the information we hold on you.

Complaints

We want the chance to resolve any complaints you have about how we process your information. You have the right to complain to the JOIC about how we have used your data.

The details for each of these contacts are:

Indigo Medical

Indigo House Surgery, 2-8 Oxford Road, St Helier Jersey JE1 4HB

Telephone +44 (0) 1534 730541 or email indigomedical@indigo.gpnet.je

Jersey Office of the Information Commissioner

2^nd Floor, 5 Castle Street, St Helier, Jersey JE2 3BT

Telephone +44 (0) 1534 716530 or email enquiries@Jerseyoic.org