Doccla Survey Privacy Policy

Last Updated: February 1st, 2024

Thank you for taking this survey about your remote monitoring experience. Your feedback helps us improve our services and develop new healthcare solutions.  This policy is an extension of the Patient Data Privacy Policy. By completing this survey, you agree that your information will be processed according to this policy and our General Privacy Policy.

1. Introduction

At Doccla UK Limited ("Doccla", "we", "our", or "us"), we are committed to protecting the privacy of patients. This Privacy Policy explains how we collect, use, and protect your personal data during the survey process.

2. Who We Are

Doccla is the Data Controller for the personal data collected during this survey. If you have any questions, you can contact our Data Protection Officer (DPO) at dpo@doccla.com.

3. How We Use Your Data

We process your survey responses to:

• Improve and develop remote monitoring services and enhance patient care
• Support product development and service enhancements
• Conduct research, training, and education
• Use aggregated insights for marketing and awareness initiatives

4. Legal Basis for Processing

We process survey responses under the following legal bases:

• Healthcare Provision (Article 9(2)(h) GDPR): Processing is necessary for medical diagnosis, healthcare, or treatment.
• Legitimate Interests (Article 6(1)(f) GDPR): To improve our services, develop new tools, and enhance patient care.
• Legal Obligation (Article 6(1)(c) GDPR): To comply with applicable healthcare laws and regulations.
• Contractual Necessity (Article 6(1)(b) GDPR): Where processing is required to fulfil a contract with you.
• Consent (Article 6(1)(a) GDPR): When you have provided explicit consent for specific uses of your data.
• Vital Interests (Article 6(1)(d) GDPR): When processing is necessary to protect an individual’s life.

5. How long we keep your data

Data is retained in in accordance with the UK Medical Devices Regulation (UK MDR 2002) and the EU Medical Device Regulation (EU MDR 2017/745), our organization retains medical device data for a period of 10 years. This retention period is determined by the classification of our medical devices, ensuring compliance with applicable laws. Data may be retained longer to comply with applicable laws.

6. Sharing Your Data

• Your survey responses may be shared with your Healthcare Provider care team, where relevant.
• In line with our General Privacy Policy, data may also be shared with approved third-party service providers, such as research partners or analytics providers, under strict data protection safeguards.
• We never sell personal data to third parties.

7. International Data Transfers

If data is transferred outside the UK or EEA, we ensure appropriate safeguards are in place, such as Standard Contractual Clauses (SCCs), to maintain data protection compliance.

8. Your Rights

Under GDPR, you have the rights to:

• Access: Request a copy of your personal data.
• Correction: Update inaccurate data.
• Erasure: Request deletion of your data where applicable.
• Restriction: Limit how we process your data.
• Objection: Object to processing based on legitimate interests.
• Data Portability: Request your data in a portable format.
• Withdraw Consent: If processing is based on consent, you can withdraw it at any time.

9. Security

Survey responses are stored securely in Doccla’s protected systems, which comply with ISO 27001, Cyber Essentials Plus, and NHS DSPT security frameworks.

10. Updates to This Policy

We may update this policy periodically. Any significant changes will be communicated via our website or other appropriate means.

If you have any questions, please contact our Data Protection Officer (DPO) at dpo@doccla.com.