Doccla Patient Privacy Notice

This notice tells you how Doccla uses information about you when we are responsible for it. If you are using a Doccla device as part of a service run by an NHS trust, the trust is responsible for your health information and their own privacy notice applies. We handle it for them, on their written instructions. If you are not sure which applies to you, ask us and we will tell you.

Summary

‍We only collect the information needed to care for you, like your contact details, health information, and how you use our service.

We use it to monitor your health, keep your healthcare team up to date, contact you when needed, meet legal requirements, and improve the safety of our service.

Your data is kept safe with strict security measures and shared with your care team, with the suppliers who run our service, and in the limited other situations set out in section 6 — never sold. Your health information is also confidential, and we treat it that way. We may also use your data to keep the service safe and working properly, to improve it, and to support research. Beyond what is needed to deliver your care safely we use anonymised or aggregated information, and we would only use information that identifies you for research if you agreed, or if a study had approval under section 251 of the NHS Act 2006.

We do not ask you to consent to us using your health information to provide your care. The law already allows it, and your care should never depend on a permission you cannot realistically refuse.

You have rights over your data, including seeing it, correcting it, deleting it, limiting its use, or requesting a copy of it (see paragraph 10 below). Questions: dpo@doccla.com

‍1. Who We Are

‍We are Doccla UK Limited (referred to as Doccla, we, us and our in this Privacy Notice), a company incorporated in England and Wales with company registration number 12206481 and whose registered office address is 184 Shepherds Bush Road, Hammersmith, London, England, W6 7NL.

We provide remote health monitoring services to help you manage your health from home. We work closely with your healthcare provider and other members of your care team to make sure you receive safe, effective, and personalised care.

The information set out in this Privacy Notice is provided to individuals whose personal data we process (you or your), in compliance with our obligations under the Data Protection Act 2018, the UK GDPR and the Data (Use and Access) Act 2025.

If you are a visitor to our website, or you contact us on behalf of a healthcare provider, this notice does not apply to you. Please see our Website and Business Contacts Privacy Notice instead.

‍2. Data Controller Details

‍We are the data controller for your information where we are the organisation responsible for your remote monitoring care, which is usually the case in our proactive care services. This notice describes what we do in that situation.

Where your care is run by an NHS trust and we provide the platform, the devices and non-clinical support, the trust is the data controller and we act as their data processor. We then handle your information only on their written instructions, and their privacy notice explains how your information is used. If you ask us for a copy of your data in that situation, we will pass your request to the trust and help them answer it.

Our contact details are as follows:

  • Address: 184 Shepherds Bush Road, Hammersmith, London, W6 7NL.
  • Email address: dpo@doccla.com (please include “Personal Data Request” in your subject heading to ensure it receives the correct attention).
  • Our Data Protection Officer can be contacted at dpo@doccla.com or at the address above.
  • Our Caldicott Guardian, who is responsible for protecting the confidentiality of your health information, can be contacted at the same address.

3. The Information We Collect and How it is Collected

‍We only collect the information we need to look after you properly. This may include:

  • Who you are — name, date of birth, healthcare number (if applicable)
  • How to contact you — address, phone number, email
  • Your health information — medical history, medications, vital signs, and care notes
  • How you use our service — data from the Doccla app (including location), call records, and feedback you give us
  • Details of a next of kin or carer, where you give them to us, so that we can contact them if we are worried about your safety

Generally, the information we hold about you comes from your healthcare provider and records they hold or from you directly by the way that you engage with us, for example by doing any of the following:

  • through engaging with us via our website or the Doccla app;
  • providing us with information in the course of using our service;
  • contacting us offline, for example by telephone, SMS, email or by post; and
  • interacting with us using social media.

Other than health data, we do not ask you for other special category information, such as details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, and genetic and biometric data, and we do not ask you about criminal convictions or offences. Some of this may still appear in the clinical notes and referral letters your care team sends us. Where it does, we handle it under the same conditions and with the same protections as the rest of your health data.

Children’s data: where we provide services in respect of a child, we process the child’s health and other personal data on the lawful bases set out in this Privacy Notice (and not on the basis of consent). Where appropriate, acknowledgements and contact details may be provided by a person with parental responsibility for the child or another person authorised to act on the child’s behalf, and we take account of the child’s age and understanding when handling their data.

‍4. How We Use Your Information, the Purpose and Lawful Grounds for Processing

‍We use your information for the following (including the purpose and legal grounds for processing your personal information):

  • Monitor your health and keep your healthcare provider up to date (Legal basis: where your care is commissioned by the NHS, the performance of a task carried out in the public interest under Article 6(1)(e) UK GDPR, read with section 8 of the Data Protection Act 2018, the task being the provision of NHS healthcare under our contract with the commissioning body; or, where you contract with us directly, the performance of that contract under Article 6(1)(b). Where an NHS trust is the controller and we act as its processor, the trust's lawful bases apply, not ours, and the trust's privacy notice explains them);
  • Contact you if your results need attention (Legal basis: If it is in our legitimate interests to do so);
  • Use the location recorded by the app, so that emergency services or a community team can be sent to the right place and so that we can support the devices. You can turn location off in your phone settings, but we may then be unable to send help to you (Legal basis: our legitimate interests in your safety and, where you are unable to tell us what you want, your vital interests);
  • Contact your next of kin, ask your GP or community team to check on you, or contact the emergency services if we cannot reach you and we are concerned for your safety (Legal basis: our legitimate interests in your safety and, where you are unable to tell us what you want, your vital interests);
  • Improve the safety and effectiveness of your care (Legal basis: If it is in our legitimate interests to do so);
  • Meet legal requirements for health services (Legal basis: Compliance with a legal obligation);
  • Improve our services using anonymous feedback (Legal basis: If it is in our legitimate interests to do so); and
  • To deliver your care safely and reliably: checking that your readings reach us and flagging when they do not, monitoring whether the app and devices are working, and tracking errors and faults so that your monitoring is not silently interrupted. This is part of providing the service you have asked for rather than something you are asked to agree to, and it continues for as long as you are using the service (Legal basis: performance of our contract and our legitimate interests in your safety, together with Article 9(2)(h) UK GDPR for the health data involved; the information the app stores on or reads from your device for this is strictly necessary to provide the service you have requested, under regulation 6(4) of the Privacy and Electronic Communications (EC Directive) Regulations 2003).

In such scenarios, we will rely on the following additional lawful basis for the processing of your health data:

  • Provision of health care (Article 9(2)(h) UK GDPR, read with Schedule 1, Part 1, paragraph 2 of the Data Protection Act 2018): where processing is necessary for the purposes of preventive or occupational medicine, medical diagnosis, the provision of health or social care or treatment, or the management of health or social care systems and services. This condition applies only where the processing is carried out by or under the responsibility of a health professional who owes a duty of confidentiality, or by another person who owes an equivalent duty of confidentiality under an enactment or rule of law (Article 9(3) UK GDPR, as provided for by section 11(1) of the Data Protection Act 2018). That covers our clinicians and the patient support staff who work alongside them.

Keeping the service safe and working properly. We use your health information to investigate faults, check that our alerts and monitoring work correctly, audit the care we provide, and carry out the safety monitoring the law requires for our medical devices. This is part of looking after you safely, not product research (Legal basis: Article 6(1)(e), and Article 6(1)(c) where the law requires it; Article 9(2)(h) for the management of health care systems and services and Article 9(2)(i) for ensuring high standards of quality and safety of health care and medical devices, read with paragraphs 2 and 3 of Part 1 of Schedule 1 to the Data Protection Act 2018).

Designing new features. Where we design new products or features to improve our care beyond what is needed to deliver your care safely, we use anonymised or aggregated data, which falls outside data protection law. For research, we would only use information that identifies you with your agreement, or where a study has approval under section 251 of the NHS Act 2006, because an Article 9 condition alone does not answer the duty of confidentiality we owe you.

‍5. How We Keep Your Information Safe

‍We take great care to protect your information. We handle your data in line with data protection laws and follow recognised industry best practices, including by taking appropriate technical and organisational measures to guard against unauthorised or unlawful processing, accidental loss, destruction or damage. For example:

  • ISO 27001 and Cyber Essentials Plus: we are certified to both standards, and we complete the NHS Data Security and Protection Toolkit self-assessment every year, so that we have appropriate safeguards in place to protect your personal information;
  • Access Controls: we have implemented safeguards in relation to access and confidentiality such that only authorised staff can access your records, and we use secure systems to keep your information safe at all times;
  • Encryption: we encrypt your data in storage and in transit;
  • Pseudonymisation: wherever we can, we remove or code details so that you cannot be identified from the data;
  • Secure IT infrastructure: is in place with monitoring and threat detection; and
  • Staff training: to support compliance with data protection best practices, including the duty of confidentiality that applies to everyone who handles patient information, whether or not they are a clinician.

However, while we will do our best to protect your personal information, we cannot guarantee the security of your information which is transmitted via an internet or similar connection.

‍6. When We Share Your Information‍

‍6.1 Sharing for your care

‍We share your health information with the people looking after you, when it is necessary for your care. That includes:

  • your GP practice and other primary care services;
  • the hospital team or NHS trust that referred you;
  • community, out-of-hours and emergency services where your care requires it; and
  • any other health or social care professional directly involved in your care.

We do this under Article 9(2)(h) UK GDPR, read with Schedule 1, Part 1, paragraph 2 of the Data Protection Act 2018, together with the Article 6 grounds set out in paragraph 4. We do not ask for your consent, because the law already allows it and your care should not depend on a permission you cannot realistically refuse.

Separately from data protection law, your health information is confidential. We share it within your care team on the basis of the relationship you have with them, which is how care across the NHS normally works. We would not share it outside your care team without telling you, unless the law required it or there was a serious risk to your safety or someone else's.

If you have asked us to involve a family member, carer or someone holding a Health and Welfare Lasting Power of Attorney, we record that and follow it. You can change your mind at any time.

If you would rather we did not share your information with a particular person or organisation, tell us. We will respect that wherever we safely can, and we will tell you if it would affect your care.

We also use other companies to operate our platform, for example hosting, our clinical record system and our customer support system. They act only on our written instructions, under a contract that requires them to protect your information to the same standard we do, and they may not use it for their own purposes. We check them before we appoint them and we keep a record of who they are, which you can ask us for.

‍6.2 Other sharing

‍Outside your care, we may share your personal data:

  • where the law requires it, including with health and care regulators and other legal authorities;
  • with regulators or fraud prevention agencies for monitoring or enforcing our compliance with legal and regulatory obligations;
  • with our professional advisers and auditors;
  • with any of our holding companies and their subsidiaries, within the meaning of section 1159 of the Companies Act 2006.

We do not share your health information for any purpose beyond your individual care without a lawful basis for doing so. Where the national data opt-out applies, we respect it: it covers uses of your information for research and planning beyond your own care.

We never sell your information.

‍7. How We Use Anonymised and/or Aggregated Data

‍We may use your data in an anonymised and/or aggregated format — information that cannot identify you — to:

  • Improve our services and patient experience;
  • Help develop new healthcare tools and features;
  • Analyse trends in patient outcomes; and
  • Support research that benefits patient care.

Such data will be anonymised and/or aggregated such that the data is not linked to you and you cannot be identified from the data.Where data cannot be fully anonymised and remains health data, we use it only to keep the service safe and working properly, or with your agreement, or where a research study has approval under section 251 of the NHS Act 2006.

‍8. International Transfers

‍We will not transfer personal data relating to you to a country which is outside the UK and EEA unless:

  • the country or recipient is covered by adequacy regulations made under section 17A of the Data Protection Act 2018 (Article 45 UK GDPR);
  • appropriate safeguards have been put in place which meet the requirements of Article 46 UK GDPR (for example using the approved International Data Transfer Agreement or International Data Transfer Addendum); or
  • one of the derogations for specific situations under Article 49 UK GDPR is applicable to the transfer. You can ask us for a copy of the safeguards we use by emailing dpo@doccla.com.

Where your care is commissioned by the NHS, we keep your health information in the United Kingdom unless the trust has agreed otherwise in writing.

‍9. Retention of Personal Data

‍We have systems in place to periodically review and delete data that is no longer being used by us for the purposes set out in this Privacy Notice. We follow the retention periods in the Records Management Code of Practice for Health and Social Care (NHS England, 2023), which for most adult health records is eight years after your last contact with the service. Unless the law requires us to keep it for longer, we keep your health records for the periods in that Code, and we keep other information only for as long as we need it. Those periods run on after your care with us ends.

If services are being provided to you pursuant to an agreement between us and your healthcare provider, we will retain your personal information for the duration of our contract with your healthcare provider, and then return or delete it as that agreement requires.

In relation to your health data, where we have an obligation to retain this data (for example, for health and safety purposes) we will retain such data for the duration required by our obligation.

Stopping the service does not delete the records we are required to keep. We will tell you plainly what we keep and for how long if you ask.

Where we no longer need your personal information, we will dispose of it in a secure manner.

In some circumstances you can ask us to delete your data: see the Your Rights section at paragraph 10 below for further information.

In some circumstances we will anonymise and/or aggregate your personal data for research or statistical purposes, in which case we may use this anonymised and/or aggregated information indefinitely without further notice to you.

‍10. Your Rights

‍In respect of the personal data about you that we are processing in accordance with the Data Protection Act 2018 and the GDPR, in certain circumstances (and provided that exemptions do not apply) you will have the following rights over your personal information:

  • right to access: the right to request certain information about, access to and copies of the personal information about you that we are holding (please note that you are entitled to request one copy of the personal information that we hold about you at no cost, but for any further copies, or for requests that are manifestly unfounded or excessive, we reserve the right to charge a reasonable fee based on administration costs);
  • right to rectification: the right to have your personal information rectified if it is inaccurate or incomplete;
  • right to erasure/“right to be forgotten”: the right to request that we delete or erase your personal information from our systems, subject to applicable exemptions (for example, we may need to retain certain data where processing is necessary for reasons of public health or for the provision of healthcare). Where we process any of your personal data on the basis of your consent (for example, marketing), you also have the right to withdraw that consent at any time; this does not affect the processing of your health data that is necessary to provide your care, which we carry out under other lawful bases;
  • right to restriction of use of your information: the right to ask us to pause or limit our use of your information in certain situations, for example while we check whether it is accurate;
  • right to data portability: where we process your personal data by automated means on the basis of a contract with you (or your consent), the right to request that we return the information you have provided in a structured, commonly used and machine-readable format, or that we send it directly to another organisation where technically feasible. This right does not apply to personal data we process on the basis of our legitimate interests; and
  • right to object: the right to object to our use of your personal information, including where we use it for our legitimate interests or for marketing purposes. Where you object, we will stop the processing unless we can demonstrate compelling legitimate grounds that override your interests, rights and freedoms (for example, ensuring your safety and the continuity of your care), or the processing is for the establishment, exercise or defence of legal claims. Our service depends on receiving information about you from, and sharing information about you with, the hospital or trust treating you, your GP practice and the other professionals involved in your care. If you object to that sharing, one of our clinicians will discuss your objection with you. If, following that discussion, you still object, we will not be able to provide (or continue to provide) the service to you, because we cannot deliver it safely without that information. This will not affect the rest of your NHS care, which will continue through your usual NHS team. To object, please contact Doccla Support or email dpo@doccla.com.

We will respond within one month. If your request is complex we may take up to two months longer; we will tell you within that first month if that happens, and why. Some limits apply to health records in particular: we may withhold information that would be likely to cause serious harm to anyone's physical or mental health, or that identifies another person, and we take advice from the appropriate health professional before we answer.

The national data opt-out: if you have told the NHS that you do not want your confidential patient information used for research and planning, we respect that choice. It does not affect the care you receive.

If your care is run by an NHS trust and we are handling your information for them, send your request to us or to the trust. If you send it to us we will pass it on and help them answer it.

If you are receiving marketing communications from us, you have the right to unsubscribe from such communications at any time by following the link in the footer of the last email you received from us or by sending your request with detailed instructions to us (see contact details above).

Please note that we do not rely on your consent to process the health data that is necessary to provide your care. Where you have given consent for an optional purpose (for example, marketing) and you later withdraw it, this will not affect your care, although it may mean you no longer receive that optional element.

If you consider our use of your personal information to be unlawful, you have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office. Please see further information on their website: www.ico.org.uk. We would rather you came to us first, at dpo@doccla.com, so that we can put it right.

If you want to use any of these rights, please email: dpo@doccla.com

‍11. Automated Decision Making and Profiling

‍We do not make decisions about your care by automated means alone, without a person involved.

‍12. Changes to this Privacy Notice

‍We may amend this Privacy Notice from time to time, for example to keep it up to date, to implement minor technical adjustments and improvements or to comply with legal requirements. We will always publish the current version of this Privacy Notice on our website, and the “last updated” line below tells you when we last changed it. If we make a change that significantly affects how we use your information, we will tell you directly.

Last updated: October 2026

‍Version 1.4: October 2026