Privacy Policy

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figado Ltd

Important information for patients

Privacy Notice, May 2018

The privacy of your data

The data protection law (GDPR…General Data Protection Regulations) comes into effect on 25th May 2018. This document sets out your rights as a patient of figado Ltd.

The document sets out the reasons for collection, use, retention and disclosure of your personal information. By personal information is meant such information which could identify you, and is directly about you. This information would be gained from yourself or has been learned as a consequence of being a patient of figado Ltd.

figado Ltd. and who we are

figado, figado Surgical are the trading names of figado Ltd. When used in this document they can be taken on all occasions along with we, us, and our, to mean, and refer to figado Ltd. figado Ltd. is a private healthcare provider incorporated as a Ltd. Company within Northern Ireland. NI registration number NI 614936.

This document tells you, the patient, the following:-

  • Why figado needs your personal information
  • How we will use it
  • Who we will share it with
  • Your rights in relation to the personal information we collect

Data Collector

The organisation which decides what personal information we will collect, and who on necessary occasions, within the confines of figado Ltd. may direct the processing of personal information to enhance our service offered to you the patient.

Data Processor

There may be circumstances when figado processes large data at the legitimate request of others, who by contractual arrangements with figado are entitled to the outcome of that processing. ie insurance companies. In these circumstances figado will take all necessary precautions to ensure that the processing of large data sets does not identify an individual patient.

Commitment to your privacy

figado Ltd. acknowledges and accepts the importance of the patients personal and confidential information and the protection of such information. This recognition will be foremost in all that we may, for the purposes of business viability, do with such information along with our legal obligations. figado will put in place or have in place such technical and procedural controls it considers may be necessary to protect personal information while it remains in the possession of figado Ltd.

Your protection within the law

The privacy of the individual is now protected by law. figado Ltd. can/will only use your personal data if it has a legitimate reason/interest for doing so. There may be occasions when figado Ltd. needs to share your information outside of figado. These are listed in the following section headed “Who will we share your personal information with”

The reasons why figado Ltd. would require to share personal information with outsiders are as follows:-

  • To provide and fulfil our healthcare contract and obligations to the patient
  • When we have a legal requirement to do so.
  • Is in our legitimate interest/s (see note below)
  • When we have sought and received the patient’s consent to do so.

Legitimate interest

When there is a business or administrative reason to use such information. This, however cannot be used as a “catch all” reason for the use of your personal information. It cannot be used, for the sake of expediency, to infringe your rights or freedoms under the law. figado does not and will not overly rely on “legitimate interest” without seeking your consent.

Types of personal information required/collected

We require personal information to allow figado Ltd. as a business, to fulfil it’s commercial function and to deliver private healthcare to our patients, maintain our records, accounts and fulfil our legal obligations.

Personal details may include:-

  • Name, address/s, phone numbers, Date of birth
  • Payment and payment method/s and details for settlement of account.
  • Insurance policy number/s and pre-authorisation number/s
  • Name of your Insurer
  • Dates of consultations
  • Dates of procedures
  • Procedure code/s
  • Medical history/records
  • Consent/s regarding the release of information to organisations involved in your healthcare provision both private and state, ie Your insurer, NHS
  • Details of those acting on behalf of and with the consent of the patient.

How and where we collect personal information

  • When you first contact figado Ltd.
  • At your initial appointment
  • When contacted by a staff member of figado Ltd.
  • As a consequence of any medical diagnosis/examination by figado Ltd.

If you do not wish to supply personal information

When you contact figado Ltd. for private medical treatment there is an implied intention to create a contract. This contract is set in a legal context which places on figado the necessity to collecting manage personal information within the law. Choosing not to supply or provide information will however delay or even prevent figado Ltd. from meeting its obligations to you. This may also mean that we cannot provide you the patient with the services we offer.

You will be notified if the refusal to supply such information, prevents us from meeting our obligations.

Who will we share your personal information with

  • The staff of figado Ltd.
  • The private clinic you have chosen to attend, and it’s staff
  • Other medical professionals
  • Your Insurer
  • The NHS
  • Other medical departments/sections within the clinics/hospitals deemed necessary in the provision of your private medical care
  • Legal bodies
  • Your appointed representative of whom we have been informed
  • Your legal guardian

Certain commercially based or third party organisations providing medical services which are not available within the clinics. Such decisions would however be made by “data controller/s” within your chosen clinic. Joint data controllers’ as they are known as have a responsibility to protect your personal data and inform you as to how your personal data will be used. (These will be in similar documents as this but issued by the providing organisations.)

Financial support agencies engaged by figado Ltd. in control of debt. (limited to financial issues and contact information only)

Personal information will only be shared with other organisations when we have a legal obligation, statutory or regulatory duty to do so and it is deemed necessary for the provision of our services and contractual arrangements with you the patient.

In the normal course of business figado Ltd. may use third party organisations known as ‘data processors’ within the data protection laws, to support the delivery of our services.

Such organisations are as follows:-

  • Mailing, email, SMS messaging , print suppliers to enable us to deliver our services.
  • Business services such as Auditors, Accountants solicitors, insurers and consultants.
  • Providers of records management, secure disposal, secure storage of IT material.
  • Providers of IT equipment systems and services.
  • Companies you may request we share your information with (only on request) by the patient.

When we share such information with our approved external organisations, our contractual arrangements with them prevents them from using your information outside of our contractual understanding or arrangements.

Where possible figado Ltd. would remove any means of individual identification from data sets or general data, prior to any processing by the above. Where this is not totally possible then the data will be so reduced to make identification unlikely.

Retention of personal information

Within the information collected or information which comes to light, during your association with figado Ltd. there will be information which will by its nature form part of your “Medical record”. It is of the utmost importance that this information be available to those providing you with medical care in the future and over time. This type of information may therefore form part of your medical record for life.

We may keep your personal information for up to 10 years for one or more of the following reasons:-

  • To respond to legitimate questions or complaints
  • To demonstrate that figado Ltd. treated you fairly and professionally.
  • To maintain documented records in line with our legal/statutory requirements.
  • For longer periods if there are legal reasons which would prevent us from destroying/deleting records.
  • Where technical reasons prevent us from doing so. In this case we will, to the best of our ability, ensure your privacy is protected.

Other information

We may keep your personal information for up to 10 years for one or more of the following reasons:-

  • To respond to legitimate questions or complaints
  • To demonstrate that figado Ltd. treated you fairly and professionally.
  • To maintain documented records in line with our legal/statutory requirements.
  • For longer periods if there are legal reasons which would prevent us from destroying/deleting records.
  • Where technical reasons prevent us from doing so. In this case we will, to the best of our ability, ensure your privacy is protected.

Your rights

Figado Ltd. can be contacted by mail at 39 Village Green, Doagh, Ballyclare, BT39 0UD.

To obtain a copy of your personal information

You can obtain a copy of the personal information we hold on you along with the following:-

  • Why we have your personal information
  • Who has access to it
  • where we obtained the information

We will respond to requests within 30 days

Updating of your information

It is important to figado Ltd. that the information we hold on you is accurate. We would ask that should there be any changes to your personal information which you consider relevant to your private medical care, that you inform us of the changes ASAP. We will take all reasonable care to ensure your information is accurate.

Request to stop using your personal information

You have the right to request us to stop using your personal information. You have the right to request us to delete, remove, or stop using your personal information if there is no reason for us to retain it. This is known as the ‘right to object’ and the ‘right to erasure’ or ‘the right to be forgotten’

It should be noted that this right can only be exercised within the context of the above section on “Retention of personal information” sub-section “Other information”

Restricted use of personal information:-

You can request that we restrict the use of your information on the grounds that:-

  • It is inaccurate
  • It has been used unlawfully but you wish us to retain it
  • It is no longer relevant
  • During the period between “the right to be forgotten” request, and our confirmation of stopping the use of your information.

Where a request for the erasure of personal information has been received in writing by figado Ltd. we will confirm that your information has been deleted. This will be in writing. You will also be informed at the same time as to why we cannot delete all or some of your personal information should this be relevant. This may be due to legal or other circumstances listed in “Retention of personal information” above.

Statement by figado Ltd.

figado Ltd. would wish to state at this point that as a private healthcare provider we do not export, sell or make available any personal information to any external organisation/s for the use or processing by that organisation in pursuance of their business. The only external organisations to which figado Ltd. will or is required to supply information is where this is necessary and essential to the provision of private medical healthcare to our patients. The sharing of your personal information will be in line with those criteria set out in the above section ‘who will we share your personal information with’

When contacting figado Ltd.

When you contact figado we will need to confirm your identity for security reasons. This is important to protect your personal information and guard against criminal activity. This identification will be carried out by a series of questions. Remember this is for your protection. Similarly when figado contacts you then you should ask any question to which we would have the answer.

Your right to complain

If in the event that you are not satisfied or are unhappy with any of our responses or you believe that we are using or not processing your personal information in accordance with current GDPR laws or regulations then you have a right to complain. This can be done through the following organisation:-

Information Commissioner’s Office (ICO) by email or by telephone 0303123 1113

Changes to this policy

figado regularly reviews and updates their privacy notice. So our patients are aware of their current rights this these updates will be published on the figado Ltd. website


Why do we use your personal informationOur reasons for processingLegitimate interests defined
• To manage the provision of services to you
• To communicate with you
• To confirm aspects of your
• To convey results
• Confirm appointments
• Our duty both legal and professional
• With your consent
• Our legitimate interests
• Fulfil our contract
• Keep our records
• The efficiency of our
• Audits by legitimate
organisations with whom we share your information
• To provide you with the services we offer
• Provide information on our services
• Our legal duty
• Fulfil our contract
• To develop future services
• Improve image of the
• Maintaining efficiency of the
• The administration of the business
• Administration of patients payments
• Administration of insurance payments
• Respond to patient settlement queries
• Fulfil our contracts
• Our legal duty
• Legitimate interest
• Maintaining patient payment records
• Manage patient financial relationship with their insurer
• The detection and avoidance of crime
• Risk management
• Comply with legal requirements
• Fulfil our contracts
• Our legal duty
• Legitimate interest
• Protection of patient interests
• Protection of figado Ltd. interests
• Our legal requirements
• To run the business in an efficient and professional way including our financial position, business capability, planning and development, communications and audit• Our legal duty
• Legitimate interests
• Complying with all our legal requirements