Privacy and Personal Data Policy

TSM health limited trading as King’s Medical Centre respects your right to privacy. This Privacy Notice explains who we are; how we collect, share and use personal information about you; and how you can exercise your privacy rights.

If you have any questions or concerns about our use of your personal information, then please contact us using the contact details provided at the bottom of this Privacy Notice.
We recommend that you read this Privacy Notice in full to ensure you are fully informed.

About Us

TSM health is a provider of Covid-19 testing, in particular, rt-PCR, antibody tests and private general medical services, headquartered in England. We offer services to individuals at King’s Medical Centre.

Services may be provided to patients under 18 years of age but may only be booked by individuals with parental responsibilities. If you are booking a test for an 18-year-old patient, please provide the patient with a copy of this notice and ensure they have understood its content.

For more information about King’s Medical Centre, please refer to our website at www.kingsmedicalcentre.london

What personal information does TSM Health collect and why?

The personal information that we may collect about you broadly falls into the following categories:

Information that you provide voluntarily

We may ask you to provide personal information voluntarily on certain parts of our Website and during the provision of Services.
TSM health processes the following categories of data for the purposes outlined above:

• Health Data: includes data about a patient’s pathology samples, the identity of the clinician requesting the test, the patient’s NHS number (if any) and health information produced as part of the test process,
• Identity Data: includes name, date of birth, ID check (passport or ID number),to register with us and order the Services,
• Contact Data: includes address, email address, and telephone number to register with us and order the Services,
• Payment system details: we do not collect your payment information such as credit card details

TSM health only processes the minimum amount of Health Data and Identity Data necessary to provide the Services.

Information that we collect automatically

When you visit our Website, we may collect certain information automatically from your device. In some countries, including countries in the European Economic Area and the UK, this information may be considered personal information under applicable data protection laws.

Specifically, the information we collect automatically may include information like your IP address, device type, unique device identification numbers, browser-type, broad geographic location (e.g. country or city-level location) and other technical information. We may also collect information about how your device has interacted with our Website, including the pages accessed and links clicked.

Collecting this information enables us to better understand the visitors who come to our Website, where they come from, and what content on our Website is of interest to them. We use this information for our internal analytics purposes and to improve the quality and relevance of our Website to our visitors.

Some of this information may be collected using cookies and similar tracking technology.

Information that we obtain from third party sources

From time to time, we may receive personal information about you from third party sources (including national airport authorities, a healthcare provider, a health insurer, an employer or other laboratories), but only where we have checked that these third parties either have your consent or are otherwise legally permitted or required to disclose your personal information to us.

In general, we will use the personal information we collect from you only for the purposes described in this Privacy Notice or for purposes that we explain to you at the time we collect your personal information. However, we may also use your personal information for other purposes that are not incompatible with the purposes we have disclosed to you (such as archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes) if and where this is permitted by applicable data protection laws.

Who does TSM health share my personal information with?

We may disclose your personal information to the following categories of recipients:

• to our partner laboratories , third party services providers and partners who provide data processing services to us (for example, to support the delivery of the services ,IT support or the Website), or who otherwise process personal information for purposes that are described in this Privacy Notice or notified to you when we collect your personal information.
• to Public Health England (PHE) for the purposes of notification of COVID 19 test results-including positive, negative and indeterminate test results, in order to satisfy the legal requirements. PHE undertakes to handle these data in accordance with the Data Protection Act 2018, General Data Protection Regulations (GDPR) and the Caldicott Guidelines;
• to any competent law enforcement body, regulatory, government agency, Local and National Health Authority, court or other third party where we believe disclosure is legally required and/or necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person;
• to an actual or potential buyer (and its agents and advisers) in connection with any actual or proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your personal information only for the purposes disclosed in this Privacy Notice;
• to any other person with your consent to the disclosure.

Legal basis for processing personal information (UK and EEA visitors only)

If you are a visitor from the UK and the European Economic Area our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it. However, we will normally collect personal information from you only (i) where we need the personal information to perform a contract with you (such as to provide the Services you have booked), (ii) where the processing is in our legitimate interests and not overridden by your rights, or (iii) where we have your consent to do so. In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person.

There may also be situations where we collect information about your health and/or genetic data when it is necessary for the purposes providing Testing services or on where it is necessary for reasons of public health. All the categories of data just mentioned are considered by European data protection law as Special Category Data.

If we collect and use your personal information in reliance on our legitimate interests (or those of any third party), this interest will normally be to: operate our Website; communicate with you as necessary to provide our Services to you; and for our legitimate commercial interest (for instance, when responding to your queries, improving our Website or Services, undertaking marketing, or for the purposes of detecting or preventing illegal activities). We may have other legitimate interests and, if appropriate, we will make clear to you at the relevant time what those legitimate interests are.

If you have other questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us by sending an email to [email protected]

Cookies and similar tracking technology

We use cookies and similar tracking technology (collectively, “Cookies”) to collect and use personal information about you.

How does TSM health keep my personal information secure?

We use appropriate technical and organisational measures to protect the personal information that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information.

International data transfers

Your personal information may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country

Specifically, our Website servers are located in the USA and our third party service providers and partners operate in Jordan. This means that when we collect your personal information we may process it in any of these countries.

However, we have taken appropriate safeguards to require that your personal information will remain protected in accordance with this Privacy Notice.

Data retention

We retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a Service you have requested or to comply with applicable legal, tax or accounting requirements) and only for as long as necessary to achieve the purpose for which TSM health holds the data.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

Your data protection rights

You have the following data protection rights:

• If you wish to access, correct, update or request deletion of your personal information, you can do so at any time by contacting us at [email protected]
• In addition, you can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. Again, you can exercise these rights by contacting us at [email protected]
• You have the right to opt-out of marketing communications we send you at any time. To opt-out of marketing (such as postal marketing or telemarketing), then please contact us using the contact details provided under the “How to contact us”.
• Similarly, if we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
• You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

Updates to this Privacy Notice

We may update this Privacy Notice from time to time in response to changing legal, technical or business developments. We will obtain your consent to any material Privacy Notice changes if and where this is required by applicable data protection laws.

How to contact us

If you have any questions or concerns about our use of your personal information, please contact us using the following details: [email protected]

The data controller of your personal information is TSM health Ltd. (company no. 8330211, registered in England at Sovereign House, Graham Road, Harrow, Middlesex, HA3 5RF).