We are committed to ensuring the security of your personal data and protecting your privacy. This policy will inform you how we look after your personal data when you use our Website and our remote patient monitoring service. It will also tell you about your privacy rights and how the law protects you.
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
Who we are
We are Current Health Limited. We are a company incorporated and registered in Scotland. Our company number is SC481544. Our registered office address is at Suite 2, Ground Floor, Orchard Brae House, 30 Queensferry Road, Edinburgh, EH4 2HS.
When we refer to “Current Health” or “we“, “us” or “our” in this policy, we are referring to Current Health Limited. We are the ‘controller’ in relation to the personal data you provide to us, which means we determine the purposes and the way in which your personal data is, or will be, processed and are responsible for it.
How to contact us
Questions, comments and requests regarding this policy are welcomed. You may write to our Data Protection Officer at:
- [email protected]
- Data Protection Officer, Current Health, Suite 2, Ground Floor, Orchard Brae House, 30 Queensferry Road, Edinburgh, EH4 2HS
About our service
Current health is a health technology company primarily serving the healthcare and pharmaceutical sectors.
Our full-service, remote healthcare platform (the “Service”) is designed to enable healthcare professionals to monitor, manage and engage patients in their homes, in hospital, or in another healthcare facility.
|Customer||means a health care organisation which we contract with to provide our Service.|
|Admin||means a senior contact at a Customer who has admin rights to access data via our Service|
|Patient||means a registered patient of a Customer|
|HCP||means a health care professional who is employed or engaged by Customer and who has responsibility for managing the care of Patients|
|Visitor||means any person who visits our Website|
|Website||means our site at www.currenthealth.com or such other site as we may use to provide our Service.|
The Service involves our data platform which allows the HCP to manage Patients via the Website.
You should be aware that our Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party sites or apps and are not responsible for their privacy statements. When you leave our Website, we encourage you to read the privacy notice of every website you visit or use.
How is your personal data collected
We use different methods to collect data from and about you including through:
|User data:||this is the email address, username, password and any other information you provide to us when you register to use the Service if you are an Admin or HCP.|
|Contact data:||any contact data you provide to us to help with queries or support on the use of the Service.|
|Correspondence data:||includes information submitted to us via our Website and details of any correspondence between you and us.|
|Feedback data:||includes any feedback you provide to us about your use of the Service including responses to surveys.|
|Technical data:||when you browse our Website, we collect some technical information about your visit to our Website, such as the IP address used to connect your computer to the internet, and browser and browser plug-in type and version|
|Usage data:||is the record of use of the Service by HCPs and Patients which is tracked and anonymised to create entirely anonymised data|
If you want any further information about how we might collect or use your personal data, please contact us.
How do we use your peronal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we have entered into with you to take steps at your request prior to entering into a contract (e.g. when you register to use our Service).
- Where we have your prior consent to use your personal data.
- Where we need to comply with a legal or regulatory obligation.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
We need to have further justification for collecting, storing and using special categories of personal data (i.e. patient records) and we have identified this where appropriate. It will normally be on the basis of your explicit consent. Please note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|Purpose/activity||Type of data||Lawful basis of processing|
|To register you as a user||User data||Necessary in order to comply with contract obligations with Customer.|
Necessary for our legitimate interests – in running our business
|To provide our Service||User data||Necessary in order to perform our contract with the Customer|
To comply with our legal obligations
Necessary for our legitimate interest – to run our business
|To manage our relationship with you. This includes responding to any questions you may ask us; notifying you of changes to the Service; notifying you of any updates to any contractual terms, privacy policies, and other relevant information||User data, Contact data||Necessary in order to perform our contract with you|
To comply with our legal obligations
Necessary for our legitimate interests – to run our business
|To identify and fix problems if they arise during your use of the Service||Contact data||Necessary in order to perform our contract with Customer|
Necessary for our legitimate interests – to run our business
To contact you to ask you to provide feedback, complete surveys or for other market research purposes and to use such information to improve our Service
|Contact data, feedback data||Necessary for our legitimate interest – to analyse and improve our Service|
– identify when you use our Website or Service
– recognise you when you return to our Service (e.g. we may show you relevant content or provide functionality you used previously)
– store information about your preferences
|Technical data||Necessary for our legitimate interests – to operate our app and to improve client interactions and user experience|
|To analyse use of the Service||Usage data||Necessary for our legitimate interest in order to assist us in analysing and improving our Service|
We will only use your personal data for the purposes for which 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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the lawful basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Disclosure of your information
We may have to share your personal information for the purposes set out above with the following third parties:
|Service providers||including those who provide:|
– Webhosting, IT, and system administration services
– Metrics and analytics
|Professional advisers||including lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance, and accounting services.|
|Authorities||including regulators and other authorities who require reporting of processing activities in certain circumstances|
|Corporate partners||includes third parties who may invest in our business or to whom we may choose to sell, transfer, or merge parts of our business or our assets. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice|
|Research partners||includes universities and other research institutions we may partner with to carry out research.|
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. 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.
Some of our external third parties may, from time to time, be based outside the European Economic Area (EEA) and the United Kingdom (UK) so their processing of your personal data will involve a transfer of data outside the EEA and UK.
If we transfer your personal data out of the EEA and UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- The country has 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.
- If we use certain service providers based out with the EEA and UK, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe and the UK. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
- In any other case, we will obtain your explicit consent before any transfer takes place.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA and UK.
We have, and continue to put in place appropriate security measures in accordance with industry best practice to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to only those employees, agents, contractors and other third parties who have a business need to know.
All information you provide to us is stored on secure servers. Where we have given you (or where you have chosen) a password that enables you to access our Service, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
How long we store your personal data for
We will only retain your personal data 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.
Where we anonymise personal data (i.e. so that it can no longer be associated with you) for further research or statistical purposes, then we may use this information indefinitely without further notice to you.
The data which is sent between HCPs and Patients using the Service and any Patient data is not retained by us and we are only processors of this data. Video calls are not recorded by us. We retain messages sent via our Service between an HCP and a Patient but only for access and review by the HCP for the purpose of managing the Patient’s health.
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If you choose not to accept our cookies, some of the features of our website or Service may not work as well as we intend.
We use the following cookies:
- Advertising cookies – these cookies are used to make advertising messages more relevant to you – Google Adwords, Microsoft, LinkedIn Ads
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Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please read through the table below to find out more about these rights.
|Your right||What this means|
|Access to your information||You have the right to ask for a copy of the information which we hold on you (commonly known as a ‘data subject access request’). This enables you to receiva copy of the personal data we hold about you and to check that we are lawfully processing it.|
|Correcting personal data|
You have the right to request that we correct personal data that we hold about you. This enables you to have any incomplete or inaccurate information we hold corrected, though we may need to verify the accuracy of the new data that you provide to us.
It is important that the personal data we hold about you is accurate and current, so please keep us informed if your personal data changes during your relationship with us.
|Deleting personal data||You may ask us to delete or remove personal data where there is no good reason for us continuing to process it. This is more commonly known as the ‘right to be forgotten’. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law.|
Please note, however, that we may not always be able to comply with your request to delete or remove personal data for specific legal reasons which will be notified to you, if applicable, at the time of your request
|Objecting to processing||You have the right to stop us processing your personal data for direct marketing purposes. We will always inform you if we intend to use your personal data for such purposes, or if we intend to disclose your information to any third party for such purposes. You could then exercise your right to prevent such marketing by contacting us.|
You may also object to us processing your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
|Restriction of processing||This enables you to ask us to suspend the processing of your personal data in the following scenarios:|
– if you want us to establish the data’s accuracy;
– where our use of the data is unlawful but you do not want us to erase it;
– where you need us to hold the data event if we no longer require it as you need it establish, exercise or defend legal claims; or
– you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
|Withdrawing consent||Where we are relying on consent to process your personal data you can withdraw your consent at any time. Please note this will not affect the lawfulness of any processing carried out before you withdraw your consent.|
|Review by an independant authoriy||You will always have the right to lodge a complaint with a supervisory body. The relevant authority in the UK is the Information Commissioner’s Office. If you do have a complaint, we would appreciate the chance to deal with your concerns before you approach the ICO, so please do contact us in the first instance if possible.|
If you wish to exercise any of the rights set out above, please contact us. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
This version was last updated in December 2021.