Last modified: 10 May 2021
Data protection legislation generally differentiates between controllers and processors of personal data to establish the responsibility for such data. It is the controller who determines the purpose and means of the processing of personal data. A processor processes personal information on behalf of a controller based on the controller’s instructions.
Trustedoctor processes personal data both as a processor and a controller. When you share data with a Service Provider through the Trustedoctor Platform (including when you receive care or other services from them), we will mostly only act as a data processor of such data, meaning that we process it “in the background” as instructed by your Service Provider while such Service Provider will be the controller of your data. In other cases, however, Trustedoctor is the controller of your data.
We may process different types of information about you for certain specific purposes.
Personal data, or personal information, is any information about a person from which he or she can be identified. It does not include data where the identity has been removed (anonymous data).
Depending on your interactions with us, we may process different kinds of personal data about you for various purposes:
We collect data that relates to your account on the Trustedoctor Platform and your relationship with us. This includes the basic data collected about you when you register for an account on the Trustedoctor Platform or otherwise communicate with us regarding your account such as your identity and contact data. Such data may include your name, date of birth, gender, photograph, geographical location, passport number, address, e-mail address, phone number, etc. It may occasionally also include your physiological data such as your height and weight. If you are a Professional User, we may also, depending on your role on the Trustedoctor Platform, collect professional data such as your job titles, employer, employment history, education, specialty, patient base, number of surgeries performed, academic recognition and professional endorsement. We use this data in order to administer and manage our relationship with you and your account, including to register you as a new user, verify your identity and create your profile, sign you up as a Professional User on the Trustedoctor Platform (if applicable), notify you about changes to the Trustedoctor Platform or our policies, market externally that you are affiliated with us (if you are a Professional User and have given us your permission), and communicate with you as necessary in order to provide you with the information, products and services that you request (such as to contact you about a request you have made and answer any queries you may have).
We may also collect your preferences in receiving marketing from us and our third
parties and your communication preferences.
We only process such data with your consent to market and promote our business and that of your Service Provider, including providing you with newsletters.
We collect usage and technical data about your visit to the Trustedoctor Platform,
including the date and time of your visit, communications metadata (such as
scrolling, clicks / button presses, and mouse-overs), any phone number used to call
our customer service number, the IP address used to connect to the Trustedoctor
Platform, your login information, settings, browser type and version, app version
and mobile operating system.
We use such data to manage our relationship with you, to administer, protect and improve the Trustedoctor Platform and for internal operations, including: (a) troubleshooting, system maintenance and support; (b) anonymising such usage and technical data for data analysis, testing, reporting, research, and statistical and survey purposes; (c) ensuring you receive information relevant to you and that content from the Trustedoctor Platform is presented in the most effective manner for you and for your devices; (d) monitoring and keeping records of our communications with you; (e) asking you to leave a review or take a survey; and (f) keeping the Trustedoctor Platform safe and secure.
We may collect financial and transactional data about you (such as some payment details and details of services you have provided or obtained on the Trustedoctor Platform). This includes receiving some limited information from our third-party payment service providers such as transaction ID, credit card number (only last four digits), total order amount, date and time of transaction and status confirmation (transaction successful or failed). We do this in order to (if required) manage payments, fees and charges, handle refunds and collect and recover money owed by you.
At times, Trustedoctor acts as a concierge to help users navigate among different
Service Providers and the services offered by them. As part of this service, we make
introductions of users of the Trustedoctor Platform, at the user's option, to
Service Providers who matches the criteria for services sought by the user.
If you make an enquiry for or sign up to a service that enables such introductions, we may, in order to provide you with the services you seek, collect health and medical data about you (such as your medical history and records), in addition to the categories of data listed above.
We do this in order to provide you with the information, products and services that you seek, including to provide you with information about Service Providers who may be suitable to provide the medical services you seek and to share your medical and other data with Service Providers as necessary for them to provide the services you request.
We also process any data about you available on the Trustedoctor Platform as necessary for us to comply with legal obligations placed on us from time to time, including to: (a) prevent prohibited or illegal activities; (b) prevent breaches of Applicable Data Protection Laws; (c) comply with our obligations relating to your personal data, including when you exercise your rights under Applicable Data Protection Laws and make requests; and (d) deal with disputes and legal claims.
We will only use your personal data for the purposes for which it was collected, 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 data for any other purpose then, unless you have already given your consent for us to do so, we will notify you, explain the legal basis which allows us to do so and where necessary ask for your explicit consent.
The Trustedoctor Platform allows you to input, upload, store, send and receive content such as text, messages and other communications, and audio, video, images, documents and other files, including medical records and written and imaging reports (collectively, “Content”) through your account.
You control your Content on the Trustedoctor Platform. We will only store your Content, keep it safe and otherwise process it in accordance with your instructions. We do not access or view your Content unless it’s necessary to comply with our legal obligations or enforce our policies, or you expressly give us permission to do so. This may be, for example, where you make an enquiry for or sign up to a service that enables you to receive introductions from us to Service Providers and have given us your permission to access your Content, or where you contact our support team for help with specific Content on your account (such as if you can’t find a file you believe should be on your account) in which case we may ask for your limited permission to look at your Content to the extent necessary.
Where we collect information about you, we may do so through direct interactions with you, automated means or other sources.
We collect data about you in different ways:
Directly from you or someone acting on your behalf. You may directly give us personal information by filling in forms on the Trustedoctor Platform or by corresponding with us by e.g. phone, e-mail or the chat function on the Trustedoctor Platform. If someone is using the Trustedoctor Platform on your behalf, they may also give us personal information about you. Depending on the services available to you this may include, for instance, your identity, contact, professional, financial and health and medical information that you provide when you register on the Trustedoctor Platform or receive our assistance in navigating among different Service Providers.
Collected by us through automated technologies or interactions with you.We automatically collect various usage, technical and transactional information about you by using cookies, server logs and other similar technologies. We may also receive technical information about you if you visit other websites employing our cookies.
From other sources. We may receive personal data about you from other users of the Trustedoctor Platform and Trustedoctor Partners. We are also working closely with third parties (including, for example, business partners, charity partners, sub-contractors for technical, payment and delivery services, analytics providers and search information providers, as well as payment service providers (currently PayPal and Braintree)) and may receive contact, financial, transactional or technical information about you from them.
We only collect personal data about children under the age of 18 with the consent of their parent or legal guardian.
We do not knowingly collect personal data about children under the age of 18 without the consent of their parent or legal guardian. If you are under 18, please make sure you have permission from your parent or legal guardian before uploading any of your personal data to the Trustedoctor Platform.
We only process your personal information where we have a lawful basis to do so. We may process special category personal data about you in certain circumstances but we only do so if, in addition to having a lawful basis, we also meet a separate condition.
In order for us to process your personal data, we need to have a lawful basis for doing so under Applicable Data Protection Laws. Our lawful basis will generally depend on the data in question and the specific context in which we collect it.
We process your personal data primarily on the following legal bases:
Contract - We will normally process your personal data only where we need this data to perform the contract we have entered into with you and be able to deliver the services you have requested from us in a secure manner (for example, to register you as a new user on the Trustedoctor Platform, contact you about a booking or order you have made and send you booking confirmation.
Legitimate interests – We may also process your personal data when it is necessary for our legitimate interests (or those of a third party). We will balance our legitimate interests against any possible impact on to you (both positive and negative), your rights or freedom. Where our interest and needs are overridden by your interests, rights or freedom, we will not process your personal data (unless you provide us with your consent or required by law). Among other things, we use your personal data to further our legitimate interests to provide you with our services and manage our relationship with you, ascertain how our customers use our services, carry out administrative and IT operations, help detect or prevent security incidents, develop our business, and generally to keep the Trustedoctor Platform safe and protect our business as well as our customers and third parties.
Legal obligation – In some cases we may also process your personal data where necessary to comply with a legal obligation, to resolve disputes or in anticipation of litigation, to enforce our agreements or to protect our rights or property or those of third parties (even if your personal data is subject to a deletion request from you).
Consent – We may also process your personal data where we have your consent to do so. Other than in certain instances where we collect special category data about you (as explained below), we will only occasionally rely on consent as a legal basis for processing your personal data. For instance, we will rely on your consent if you have agreed to us sending direct marketing communications to you. You have the right to withdraw your consent at any time by contacting us.
Please note that if you receive care or other services from Service Providers on the Trustedoctor Platform, such Service Provider will rely on their own lawful bases for processing your data.
However, we may also at times, depending on the services you use, collect and process special category data about you, such as health and medical information. This will typically be if you make an inquiry for or sign up on the Trustedoctor Platform to a service that enables you to receive introductions from us to Service Providers. We need to do this in order for us to assist you in identifying a Service Provider who is suitable to provide you the services you seek and to ensure they are provided with sufficient information about your case to provide the appropriate care. To lawfully process such special category data, we must, in addition to having a lawful basis, meet a separate condition for the processing. We only process special category data if:
we have your explicit consent to do so; and/or
it is necessary to bring or defend legal claims.
Opting out of newsletters or marketing messages will not prevent us from contacting you for other purposes.
If you have consented to receiving newsletters or marketing messages from us, you can ask us to stop at any time by following the opt-out links on the relevant newsletters or messages or by contacting us. Where you do so, this will not apply to personal data provided to us for other purposes and we will still use your contact information to communicate with you for other purposes (e.g. regarding an appointment you have booked).
We may share your personal information with certain third parties.
We never sell or allow your personal information to be used by third parties for their own marketing purposes.
Service Providers or other users of the Trustedoctor Platform. Depending on the services you use, we may, when you ask us to do so or otherwise with your consent, share your personal information with Service Providers or other users of the Trustedoctor Platform. All Professional Users have undertaken to us that they will comply with all privacy and security laws applicable to your interactions with them. However, we are not responsible for any violations of privacy and security laws by any Service Providers or other users of the Trustedoctor Platform. Where you choose to share or consent to us sharing your data with any third parties that are not under our control (including other users of the Trustedoctor Platform), they are responsible for such data. How they handle your data is determined by their policies and local regulations and we recommend you read them.
Your parent or legal guardian, or other persons who use your account. If you are a minor or do not have legal capacity, we may share your personal information with your parent or legal guardian supervising your use of the Trustedoctor Platform. We may also share your information with other persons who use your account unless we believe they are not authorised to do so.
Third party service providers who help us run our business and provide services to you on our behalf. This includes IT suppliers (including suppliers of data storage and web hosting services), maintenance and database management providers, analytics providers as well as other service providers and select contractors where it is necessary for us to operate or optimise the Trustedoctor Platform and for the administration of services on it. Where we engage such third-party service providers, they will be acting as processors on our behalf to carry out such data processing functions, meaning they will access and use this data to provide services to us only in accordance with our instructions and must provide reasonable assurances that they will appropriately safeguard the data and treat it in accordance with Applicable Data Protection Laws. We require all such service providers to respect the security of your personal data and to treat it in accordance with the law.
Professional advisers. This can include lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services, acting as processors or controllers of your information.
Regulators, governmental bodies and any other person where we are required to for legal reasons. We may disclose or share your personal data with, for example, regulators, law enforcement and other authorities who require reporting of processing activities in certain circumstances, courts or other relevant persons (acting either as processors or controllers) (i) if we reasonably believe that disclosure is compelled/required by applicable law, regulation, legal process or a government request, (ii) to establish, exercise or defend our legal rights, (iii) to enforce our agreements and policies, (iv) to protect the security or integrity of our business and services, or (v) to protect our rights, property, or safety or those of our customers or others. This includes exchanging information with other companies and organisations for the purposes of preventing fraud and reducing credit risk.
Acquirors or successors. If Trustedoctor Ltd. merges with a third party or its shares or substantially all of its assets are acquired by a third party (through e.g. a sale, merger, reorganisation or similar event), personal data held by us about our customers will likely be one of the assets transferred to the buyer or successor entity in order to maintain service continuity under our contracts with such customers. In such an event, we will take steps with the aim of ensuring that your privacy rights continue to be protected.
Our business or charity partners where the data has been aggregated or anonymised and can no longer be linked to you as an individual. Occasionally we may anonymise your personal data or aggregate it with other data (such as in charts or tables) so that it can no longer be associated with you (if such data includes sensitive data about you such as health data, we will only do so with your explicit consent). We may do this for analysis, research or statistical purposes, to improve our services or for systems administration purposes. In accordance with Applicable Data Protection Laws, we may share such anonymous or aggregated information with third parties indefinitely without your consent or further notice to you.
We may also share your personal data with any other person where we have obtained your explicit consent to do so.
Your personal data is stored using secure cloud-based storage on servers in the EEA and the United Kingdom. We do not transfer your data outside this area except in certain specific situations, and then only if sufficient safeguards are in place.
We do not store your personal data on your computer or mobile device. All your personal data is securely stored in the cloud.
The cloud storage servers we use to store your data are based in the European Economic Area ("EEA") and the United Kingdom. We do not transfer or store your personal data outside this area except in certain specific cases. This will typically be where you interact or communicate with a Service Provider or a user of the Trustedoctor Platform who is located outside the EEA or the United Kingdom in connection with the provision or receipt of services, in which case we may transfer your personal data to them as required in connection with those services.
In addition, your data may be transferred outside this area in connection with the provision of services by third-party service providers who act as processors on our behalf and help us enable some of the functions of the Trustedoctor Platform. For example, we use a chatbot business-messenger service to enable live chat and messaging functionality on the Trustedoctor Platform to provide tech support to users. This service is provided by a third-party provider whose servers are based in the United States. The video provider we use to enable video consultations on the Trustedoctor Platform is also based in the United States. While no video or audio media is permanently stored on any of the video provider’s servers, such media may in certain circumstances be temporarily stored in flash memory in the United States for the duration of the video/audio session. We may also use certain other third-party service providers from time to time. We have safeguards in place with all these providers to ensure your data is adequately protected.
In the limited circumstances where we transfer your personal information outside the EEA and the United Kingdom, we will only do so in accordance with Applicable Data Protection Laws, that is, if we can ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is in place:
the country to which your personal data is being transferred has been deemed to provide an adequate level of protection for personal data by the European Commission (or, in the case of transfers from the United Kingdom, the competent authority for the United Kingdom);
our contracts with the recipient include standard contractual clauses approved by the European Commission (or, in the case of transfers from the United Kingdom, by the competent authority for the United Kingdom) which give personal data the same protection it has in Europe; or
an alternative data transfer mechanism that ensures sufficient safeguards for such transfer in compliance with Applicable Data Protection Laws (including any new version of the EU-US Privacy Shield adopted pursuant to Applicable Data Protection Laws) is in place.
Please contact us if you want more information about partners we may use who store data outside of the EEA and the United Kingdom or further information on the specific mechanism used by us when transferring your personal data out of this area.
If none of these safeguards are available in respect of a proposed transfer of your personal data outside the EEA and the United Kingdom, we will explain the possible risks to you of the proposed transfer, following which, if you provide your explicit consent, we may proceed with the transfer.
Your personal data may also be transferred and stored outside the EEA and the United Kingdom by Service Providers (or their processors) or by independent third-party suppliers (such as payment service providers). Such transfers are outside our control and you should refer to their privacy notices for more details.
We do not take solely automated decisions about you using your personal data.
We do not make any kinds of solely automated decisions about you (meaning decisions made without any human involvement) which could affect you in legal or similarly significant ways.
We have implemented security measures to safeguard your personal information.
Our staff only have access to your personal information to the extent they need it in order to provide you with access to the Trustedoctor Platform and the services available on or through it.
Communications (including those containing sensitive medical records like operations, habits, permanent medication, drug allergies and permanent diagnoses) internally between our servers (e.g. between application server and databases) are handled via secure socket layer (“SSL”) encryption, providing an industry-standard level of protection for data in-transit. You should always make sure that your browser can validate the Website’s certificate. All uploaded data is stored in encrypted form and the encrypted values generated are signed using a message authentication code (MAC) so that the underlying value cannot be modified once encrypted.
The cloud storage provider that we use has certifications for compliance with the leading security frameworks/standards and holds an array of security compliance certifications, including ISO 27001 (one of the most widely recognised, internationally accepted independent security standards), SOC 1, FISMA, FedRAMP, PCI DSS Level 1, ISO 9001 and ISO 27018. In addition, the provider aligns its HIPAA risk management program with FedRAMP and NIST 800-53, which are higher security standards that map to the HIPAA Security Rule.
All data travelling between your device and our cloud servers is also encrypted using industry standard methods.
Any payment transactions will be processed securely by Paypal or, if you opt for payment via credit card, Braintree (a division of Paypal).
Where we have given you (or where you have chosen) a password to access the Trustedoctor Platform, you are responsible for keeping this password confidential. Your passwords are stored on our servers in encrypted form using a one-way hashing algorithm and you can opt to use two-factor authentication (2FA) to login and access your account. Please be reminded that you must protect any passwords or other credentials associated with your account.
You should be aware that the transmission of information via the internet is never completely secure and we cannot guarantee the security of your data transmitted to the Trustedoctor Platform, although we will do our best to protect your personal data. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
Your payments are handled by third-party payment service providers who operate independently of us and we are not responsible for their handling of your data.
Any payments made on the Trustedoctor Platform are handled by third-party payment service providers who operate independently of us. We currently use PayPal and Braintree (a division of PayPal (Europe) S.a.r.l. et Cie, S.C.A.) to handle such payments. PayPal offers mobile and web payment systems for online vendors and Braintree is a PayPal service that handles credit card payments. If you choose to make a payment for a product or service on the Trustedoctor Platform, you will be re-directed to the relevant service provider and will provide your information directly to them. We will also transmit certain data (such as price, currency and unique user ID (client token)) to them. They will process all such data for the purpose of payment processing as an independent controller. We may also receive some limited information from them about you such as transaction ID, credit card number (only the last four digits), total order amount, date and time of transaction and status confirmation (transaction successful or failed)). All processing by PayPal / Braintree (or any other third-party service provider as designated by us from time to time) is governed by their own privacy policies for which we are not responsible. You can access the Privacy Statements of PayPal and Braintree via the following links:
We will not retain your data for longer than is necessary to fulfil the purposes for which it was collected or is processed, or in line with any legal requirements.
You are in control of and can delete the Content on your account at any time. If you do so, it will no longer be accessible to you or others who may access your account. You should be aware that if you share any Content with another user of the Trustedoctor Platform, copies of such Content may be accessible to them through their accounts even after you delete it from your account.
However, even after you or we delete any of your information, we may retain minimised logs of your account activity for longer periods for legal reasons.
We may occasionally anonymise your information so that it can no longer be associated with you (which, if it includes sensitive data such as health data, we will only do with your explicit consent), for research or statistical purposes, in which case we may use this information indefinitely without further notice to you. For more details about our retention policies, please contact us.
You have certain rights regarding your personal information.
You have certain rights in relation to your personal information, including the following:
The right to object to processing
You have the right to object to the processing of your personal data in certain situations. You have an absolute right to stop your personal data being used for direct marketing.
The right to information
The right of access
You have the right to request access to your personal data held by us. You also have the right to request a copy, and we will provide you with this unless legal exceptions apply. Certain other people also have a statutory right to apply for access to your health records in case of your death under the Access to Health Records Act 1990.
The right to rectification
If the personal data that we process is incomplete or incorrect, you have the right to request their completion or correction at any time, though we may need to verify the accuracy of the new data you provide to us.
The right to erasure (also known as the "right to be forgotten")
You have the right to request that we delete your personal data. This is not an absolute right and only applies in certain circumstances, for example, we cannot delete information if there is a legal or regulatory obligation on us to keep it.
The right to restrict the processing
You have the right to request that we restrict the processing of your personal data in certain situations: a) if you contest the accuracy of your Personal Data, you may request that its processing is restricted while we verify its accuracy; b) If the processing of your Personal Data is considered unlawful, but you do not require the deletion of your Personal Data; c) If we no longer need the data for the purposes of its processing, but you need it for the establishment, exercise or defence of legal claims; d) If you object to our processing of your data based on our legitimate interests.
The right to data portability
You have the right to request that we provide your personal data to you in a machine-readable format. This right can only be used where the data is held electronically and the processing relies on consent or contract and is carried out by automated means.
Your rights in relation to automated decisions making and profiling
You have the right to object to decisions based exclusively on the automated processing of your personal data. We do not engage in profiling or any processing related to automated decision-making activity.
The right to withdraw your consent
If your personal data is processed based on your consent, you have the right to withdraw your consent at any time. If you withdraw your consent, this will not affect the lawfulness of how we used your personal data before you withdrew consent, and we will let you know if we can no longer provide you with your chosen service.
You will generally not have to pay a fee to exercise any of your rights as a user, although we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. We could also refuse to comply with your request in these circumstances.
When you make a request to exercise your rights, we may need to ask for proof of your identity and/or ownership of your account before fulfilling your request. We may also contact you to ask for further information in relation to your request.
Please note that if your request pertains to data that you have shared with a Service Provider, such Service Provider will be responsible for granting your request.
We are not responsible for data collected by third party websites that link from the Trustedoctor Platform.
If you are not satisfied with our response you can contact the UK's Supervisory
Authority, the Information Commissioner's Office (ICO) in the UK:
Information Commissioner's Office, Wycliffe House, Water Lane, SK9 5AF, Cheshire, United Kingdom
Phone: 03031231113 (local rate) or 01625545745 (national rate), www.ico.org.uk
Trustedoctor Ltd. is registered with the Information Commissioners Office, registration number ZA217178.
the Trustedoctor mobile application software
Applicable Data Protection Law
all data protection laws, regulations and orders relating to the privacy, security, confidentiality and integrity of personal data and the privacy of electronic communications that is applicable to our processing of your personal data, including the EU General Data Protection Regulation 2016/679 (GDPR) and any corresponding national laws and regulations
any content, such as text, messages and other communications, and audio, video, images, documents and other files, including medical records such as X-ray and imaging reports, that a user inputs, uploads, stores, sends or receives through their account on the Trustedoctor Platform
as defined in Applicable Data Protection Laws (this typically means a person or entity who, alone or jointly with others, determines the purposes and means of the processing of personal data)
Personal data (or personal information)
as defined in Applicable Data Protection Laws (this typically means any information about a person who is or can be identified from that information, directly or indirectly (e.g. by reference to an identifier such as a name or location data))
as defined in Applicable Data Protection Laws (this typically means any operation performed on personal data such as collection, organisation, storage, transfer, alteration, retrieval, use, disclosure or erasure)
as defined in Applicable Data Protection Laws (this typically means a person or entity who processes personal data on behalf of the controller)
a patient, policyholder, customer or other service recipient registered on the Trustedoctor Platform for the purpose of receiving services from Service Providers
a health specialist, expert, doctor, dietitian, insurance provider, administrator, other healthcare professional or individual such as an adviser or coach registered on the Trustedoctor Platform for the purpose of providing medical or health-related services or assistance
collectively, Professional Users and Trustedoctor Partners
Special category data (also referred to as sensitive data)
as defined in Applicable Data Protection Laws (this typically means personal data relating to race, ethnic origin, politics, religious or philosophical beliefs, trade union membership, genetics, biometrics (where used for ID purposes), health, sex life or sexual orientation)
Trustedoctor (or TD)
Trustedoctor Limited, a company incorporated in England and Wales with registered number 10228675 and whose registered office is at Franklin Building, 124 Goswell Road, London, Greater London, United Kingdom, EC1V 7DP
an individual or entity who has entered into a contract with TD to provide or offer various healthcare and/or related services who employ or are otherwise affiliated with certain Professional Users (and on whose behalf such Professional Users provide their services to Private Users)
Trustedoctor Platform (or Platform)
the Website, the App, any other Trustedoctor product and the services that Trustedoctor provides on, through or in relation to them
the website Trustedoctor.com or other Trustedoctor owned, operated, licensed or controlled websites and their respective sub-domains