Effective: 9th February 2021
Effective: 9th February 2021
Privacy and information governance is the backbone of good software services, particularly in healthcare.
This Privacy Notice explains how we handle personal information about our users in health and care organisations, and how we handle personal information about their patients. This notice also contains information applicable to job candidates, employees, and contractors.
Visconn Limited operates a specialised platform, “Visconn Clinic”, that is used to manage communications and information in health care and social care systems, with the potential of linking the information across multiple health care or social care organisations.
Typically, we are data processors for the health care or social care organisation, based on our data processing agreement.
This policy applies to our software, website, and services. We’ve tried to make it easy to read, but if you do find anything unclear, please get in touch.
Our full company name is Visconn Limited and our:
- Office is at Mallard House Stanier Way, Chaddesden, Derby, England, DE21 6BF
- Company Registration Number is 02868962
- ICO Registration Number is Z9720852
- NHS Data Security and Protection Toolkit Organisation Code is E8T6V
You can send any questions about privacy to firstname.lastname@example.org
Health and care professionals can request for a Visconn Clinic account.
When you do so, we collect the following information about you and link them to a unique identifier in our system:
- Email address
- Affiliated Organisation Name
Through the use of our software platform, Visconn Clinic, the following information will be collected from you when required:
- Affiliated organisation
- Job role
- The content of communications with, or about, patients sent via Visconn Clinic
- Data about the way you have used Visconn Clinic software, such as the functions you’ve used, and the devices and software you used to connect to Visconn Clinic
We collect this data to provide you with software services that your organisation has agreed for us to provide to them, as governed by our Terms and Conditions and any contractual relationship we have in place with them.
Visconn software services are a communications platform that enable you to communicate with patients directly or communicate with other health and care professionals.
We may also use your contact details to tell you about other solutions that we have built for the NHS or social care services that we think your organisation may be interested in, subject to your right to object to direct marketing.
When your health and care organisation use our software to communicate with you, they provide us with information they hold about you, so that we can make sure you receive those communications.
Depending on the software services used by your provider, the information we handle on their behalf will vary. At a minimum, when our software is first used in relation to any communication about you, we will safely store and use the following information about you:
We use the following contact information when health and care professionals communicate with you using our software:
- Mobile phone number
- Other contact phone numbers (if applicable)
- Email address
We use this information to enable your health and care provider to communicate with you, either through SMS and email messages sent on our platform, or for them to call you.
We safely collect, store and transmit communications sent to you through Visconn Clinic software for health and care organisations. These communications may include:
- Messages from these health and care providers (e.g. your GP)
- Links to secure meeting rooms for video consultations.
- Information about the devices and software you use to connect to our Services.
When explicitly instructed, we use information from clinical records in other systems to which your health and care provider has access. We do this in order to make those records available to your provider or to other professionals involved in your care.
Visconn Clinic also collects usage data, such as when you open and close our software, what product features you use and what computer you are using.
This allows us to provide clear audit trails and diagnostics, so that we can improve our software and maintain the clinical safety of our products and services.
We also monitor the functioning of our software to prevent fraud, cyberattacks and other dishonest behaviour.
We process corporate prospects’ contacts or past corporate clients’ contact data, including for direct marketing purposes, subject to the right to object and any opt-out exercised.
The video consultation service is hosted by us, Visconn Limited, but runs on a video conferencing engine called Pexip Infinity. This engine is fully hosted and managed by Visconn Limited. A unique URL to the video consultation is generated and all participants are visible in the consultation, no third party can ‘listen in’.
The video and audio communication of the video consultation is only visible to participants on the call and is not recorded or stored on any server (not Visconn Clinic’s and not on any third party’s servers).
All communication between the user’s browser, or the patient’s browser, and Visconn Clinic service is transmitted over an encrypted connection (secure web traffic using HTTPS and TLS or secure websocket traffic or secure WebRTC).
As long as both the clinician and patient are using their computer devices in the European Economic Area, it is guaranteed that any data hosted on a server is within the EEA in line with NHS best practice guidelines on health and social care cloud security.
The only data related to the call that may be stored by us is metadata to provide additional context about the way the service is being used. The usage data may include call participant’s browser type and version, operating system, length of call; as well as information about the timing, frequency, and pattern of the service use. The IP address of call participants may also be stored as part of this usage data. No other personal information of call participants is collected or stored.
Visconn Limited always acts as a data processor in relation to patients’ data that providers share with Visconn Clinic through the use of its software services.
Health care providers’ lawful basis for processing patient data using Visconn Limited services is expected to be:
- Article 6(1)(e) – ‘…exercise of official authority…’;
And their processing of special categories (health) data using Visconn Limited services, the conditions are expected to be:
- 9(2)(h) – ‘…health or social care…’, and
- 9(2)(i) – ‘…public health purposes…’.
Anyone using Visconn Clinic for purposes beyond those set out above are likely to be misusing the software and in breach of the terms and conditions.
Our other legal bases for processing personal data where we are data controllers are to perform our contract to provide a service, when the contract is with you (GDPR Art. 6 (1)(b)), or our legitimate interests, provided they are not overridden by your individual interests, rights and freedoms surrounding data protection GDPR Art. 6 (1)(f).
We use third-party data processors, such as our email, communications, and storage providers.
We compile anonymised statistics about the use of our platform, such as the use of different features by our users. All personal data is removed by aggregating the data to practice level or above. We share these aggregate usage statistics with third parties. These third parties include:
- National bodies including NHS Digital, NHS England, and relevant government departments.
- Local commissioning bodies such as CCGs.
Patients’ data is generally kept in line with the Records Management Code of Practice for Health and Social Care 2016. However, Organisations can also override this and define their own Retention Period.
We retain the data pertaining to our clients’ and prospects’ medical teams’ members and to non-medical personnel actually or potentially involved in purchasing our services for as long as necessary for the purpose of providing the service, to pursue a sales transaction, or to market our services, subject to their right to object or not to be subject to direct marketing. You may also contact us (email@example.com) to request that we delete the data that we hold about you.
If you have questions or concerns about privacy, or wish to exercise rights you have in relation to personal data we process about you, you can email firstname.lastname@example.org
This notice may change periodically and will be published on the Visconn website.