Patient Advice

Complex Spine London is a limited company registered in England under company number 05099246.

Registered Address              :           84 Broad Walk, Blackheath, London, SE3 8ND

Trading Address(s)              :          

1. Tower 43, 25 Old Broad Street, London, EC2N 1HN
2. 33 Cavendish Square, London, W1G 0PW
3. 1 Canada Square, London, E14 5DY
4. 4 Harley Street, London W1G 9PB
5. 239 High Street Kensington, London, W6 6SA
6. Putney Bridge Approach, Putney, London, SW6 1NB

7. See our website for details of hospitals and clinics that our consultants and healthcare professionals work from

Data Protection Officer(s)    :           Dr Richard Schoub

                                                            Mr Will Beattie

Email Address                       :           dataprotection@complexspine.london

Telephone Number               :           020 3950 2409

Correspondence address    :           84 Broad Walk, Blackheath, London, SE3 8ND

We are regulated by The Health and Care Professions Council and The General Medical Council. We are members of The Chartered Society of Physiotherapists, British Medical Association and British Association of Spinal Surgeons.

This Information explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.

Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

The personal data that we use is set out in Part 5, below.

Under the GDPR, you have the following rights, which we will always work to uphold:

11. The right to be informed about our collection and use of your personal data. This information should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 11.
12. The right to access the personal data we hold about you. Part 10 will tell you how to do this.
13. The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 11 to find out more.
14. The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details in Part 11 to find out more.
15. The right to restrict (i.e. prevent) the processing of your personal data.
16. The right to object to us using your personal data for a specific purpose or purposes.
17. The right to data portability. This means that, if you have provided personal data to us directly, we use it with your consent or for the performance of a service, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
18. Rights relating to automated decision-making and profiling. We do not use your personal data in this way.

For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 11.

Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.

We may collect some or all the following personal data (this may vary according to your relationship with us;

• Name
• Date of birth
• Gender
• Marital Status
• Address
• Email Address
• Telephone Number
• Healthcare Insurance Provider or Source of Funding
• Job Title
• Profession
• Detailed medical and healthcare history
• Information held by other medical or healthcare individuals or organisations
• Next of kin information
• Payment Information

Your personal data may also be obtained from the following third parties;

• Referrer e.g. General Practitioner, Hospital Doctor, Physiotherapist etc.
• Hospitals/Clinics that we offer our services from
• Your insurance provider
• Your funding agent e.g. health office, embassy etc.
• Our external marketing agents e.g. Google, Facebook etc.
• Private and Self-Funded Patients’ Concierge Services

Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a service with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data may be used for one of the following purposes;

• Help us manage your spinal condition
• Obtain information about your spinal condition to medical or healthcare professionals who are also managing your care
• Provide information about your spinal condition to medical or healthcare professional who are also managing your care
• Communicate with you, which may include responding to phone calls, emails or letters
• Supply you with information about your spinal condition that you have opted-in to for e.g. obtaining patient information leaflets, procedure leaflets or other information that will be useful to you

Marketing and Promoting Our Service to You

With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email and/or telephone and/or text message and/or post with information, news or offers on the services that we supply. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you can always opt-out.

We will not keep your personal data for any longer than is necessary considering the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):

• All data will be kept for a minimum of seven (7) years from when you no longer require our service or are discharged as client/patient from our care
• All data for children under the age of 18 years of age will be kept until they reach 25 years of age i.e. a minimum of seven (7) years
• This is line with regulatory arrangements for keeping medical and healthcare data in England and Wales
• Once your data is no required to be kept, it will be securely deleted

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All our data storage and transfer is managed by Encrypted Work and Sealit Encryption, a UK Government certified provider which allows email and document classification; email and file encryption; secure managed file transfer, secure online collaboration, auditing and compliance reporting. This enables us to protect your data and share information securely throughout its lifecycle. For further information about Encrypted Work go to https://encryptedwork.com and https://sealit.id We will only store your personal data in the UK. This means that it will be fully protected under the GDPR.

All paper records of your personal, medical and healthcare data are stored in a locked, fire-resistant cabinet in the trading addresses as given in Part 1.

All electronic data is stored using Encrypted Work and Sealit Cloud-based storage systems in the UK. This cloud uses identity-based AES 256-bit encryption at rest using FIPS 140-2 approved cryptographic data libraries.

We will only transfer your personal data between our administrative, IT, marketing medical and healthcare teams to allow us to provide a service to you. In doing so, we will use the email and file encryption service by Encrypted Work and Sealit. Data is encrypted in transit using TLS, which provides highest security for end-to-end data exchange.

Please contact us using the details below in Part 11 for further information about the data protection mechanism used by when storing and transferring your personal data within the UK.

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We may sometimes contract with the following third parties to supply specific services to you on our behalf. These may include data storage/transfer, payment processing, communication, delivery, and marketing. In some cases, those third parties may require access to some or all your personal data that we hold. These third parties include;

• Encrypted Work Encryption
• Sealit Encryption
• World Pay – card payment collection company
• I-Zettle – card payment collection company
• MidexPro– medical and healthcare bill collectors
• LCN – website hosting
• Vonage (VOIP) – voice over internet phone
• Dragon Dictate – medical transcription software
• E-Transcriptions – UK Cloud based transcription service
• Cashflow 2 Healthcare (CF2H)

All these third-party providers comply with GDPR regulations.

If any of your personal data is required by a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 8.

If any personal data is transferred outside of the EEA, we and our third-party service providers will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR, as explained above in Part 8.

In some limited circumstances, we may be legally required to share certain personal data, which might include yours for e.g., if we involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 11. To make this as easy as possible for you, a Subject Access Request Form is available for you to use. This can be found on our website www.complexspine.london.

You do not have to use this form, but it is the easiest way to tell us such that we can process your request as quickly as possible.

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

We will respond to your subject access request within 28 days and, in any case, not more than one month of receiving it. Normally we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of the progress of your request by your data protection officer.

To contact us about anything to do with your personal data, data protection and privacy information, including to make a subject access request, please use the following details:

Email address: dataprotection@complexspine.london

Telephone number: 020 3950 2409

Postal Address: Data Protection Officer, Complex Spine London, 84 Broad Walk, Blackheath, London, SE3 8ND

We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.

Any changes will be made available on our website www.complexspine.london under the heading data protection.