About this Privacy Notice

This Privacy Notice sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us in accordance with UK data protection legislation.

We may need to update this Privacy Notice from time to time and where we are already processing your personal data we will notify you of any significant changes.  

Who we are

Proton Partners International Limited is a Company registered in England and Wales (company number 09420705).  We are a registered data controller with the Information Commissioners Office, registration number ZA213326.

A company formed by UK based and international cancer and healthcare specialists, we operate a network of oncology centres nationally and internationally, providing a range of cancer services for patients through our subsidiary company, The Rutherford Cancer Centres Limited http://www.therutherford.co.uk/about-us/Proton Partners International Limited set the strategy for Rutherford Cancer Centres and provide The Board, Executive Team, corporate governance, finance, marketing, governance, human resources, business development, and health and safety provision for all subsidiary companies within the group.

Where the term ‘we’ or ‘us’ is used, this relates to Proton Partners International Limited.

Other company subsidiaries within the Proton Partners International Limited Group are:

  • Rutherford Estates Limited
  • Rutherford Diagnostics Limited
  • Rutherford Innovations Limited.

Our nominated representative, for the purpose of the Data Protection Act, is our Data Protection Officer whose contact details can be found at the end of this notice.

Processing personal data in line with data protection legislation

We will process your personal data in line with data protection legislation as follows:

  • We will always process personal data lawfully and fairly and in a transparent manner. We will ensure this Privacy Notice is available on our website and, where relevant to your relationship with us, ensure information is included in contracts, application forms and agreements where our relationship with you requires us to process personal data.
  • We will ensure that whenever we collect personal data it is adequate, relevant and not excessive in relation to the purpose for which it is being processed.
  • We will ensure information processed is accurate and where necessary kept up to date
  • We will ensure that your personal data is kept in a form that allows us to identify you for our business purposes but is not kept in an identifiable format for longer than is needed.
  • We will ensure that the processing of your personal data is done so to ensure the security and confidentiality of the data. This means that we have policies, procedures and training in place to ensure robust security controls are applied to the processing of your data.

What is personal data?

The term ‘personal data’ relates to any information that can, or has the potential to, identify you as an individual such as your name, address, e-mail address, phone number. It also includes less obvious information such as identification numbers, electronic location data and other online identifiers.

Certain types of personal data are referred to in data protection legislation as ‘special categories’ of data. This is because they are classed as more sensitive and require additional protection.

Such information includes information about an individual’s:

  • Race
  • Ethnic origin
  • Politics
  • Religion
  • Trade union membership
  • Genetics
  • Biometrics (where used for identification purposes)
  • Health
  • Sex life
  • Sexual orientation

What personal data do we collect?

Business Activities

In the normal course of day to day business activities we may obtain personal data through:

  • Enquiries entered onto our online forms, by email, telephone or letter which may include and not limited to enquiries in relation to:
  • Investment opportunities
  • Contracting of services both by us and to us
  • Registration for events
  • Subscriptions to newsletters
  • Complaints
  • Job vacancies
  • Healthcare services

Enquiries in relation to Rutherford Cancer Centres Limited

Enquiries received by letter, email, fax, completion of website forms that relate to services delivered from Rutherford Cancer Centres Limited are directed to Rutherford Cancer Centres Limited and information in relation to the enquiry is not retained by Proton Partners International Limited. Information on how your personal data is processed by Rutherford Cancer Centres is provided in their Privacy Notice at http://www.therutherford.co.uk/privacy-policy/.

Governance of Rutherford Cancer Centres Limited 

The Board and Executive Team of Proton Partners International Limited set the strategy and provide the corporate and quality governance and central functions in relation to Rutherford Cancer Centres. This means that we may have access to personal data processed by Rutherford Cancer Centres Limited as follows:

  • Accounting and Invoicing

When you enquire about treatments and services at Rutherford Cancer Centres or receive treatment, the finance department at Proton Partners International will have access to your personal data in order to provide quotations to you or to generate invoices. Personal data processed for this purpose will include:

  • Name, address and date of birth
  • Reference number
  • A description of the treatment applied for or received

Only personal data that is necessary in order to undertake the accounting and invoicing process will be accessed by those that undertake these roles. To be able to undertake this type of processing personal data may need to be exchanged with organisations that are responsible for payment (e.g. insurers, NHS bodies, agencies).

  • Governance and Audit on Rutherford Cancer Centres

Proton Partners International Limited are responsible for ensuring that safe management of services within Rutherford Cancer Centres is in place.  Roles within Proton Partners International may have access to patient data in the following circumstances:

  • To investigate Incidents and complaints
  • To undertake quality and clinical audits
  • Financial auditing
  • Accounting and invoicing

Types of personal data processed by us may include:

  • Personal data in relation to employees and contractors for the purpose of fulfilling employment law requirements.
  • Personal, special category data and professional information required for processing job applications.
  • Personal and special category data in relation to patients accessing services at Rutherford Cancer Centres for the processing of payments, audits, complaints and incidents.
  • CCTV images of visitors attending our physical locations.
  • Contact details of suppliers and contractors (e.g., name, company name, job title, address, telephone numbers, work and personal email and postal address).
  • Financial information required for processing payments to individuals and companies.
  • Personal information in relation to investors.

What is our lawful basis for processing your personal data?

Under data protection legislation we must always have a lawful basis for using personal data and special category data (as described earlier). The law provides a set of lawful purposes for processing personal data and special category data. 

Depending on the reason for us processing your personal data, there may be several lawful purposes that will apply, and which may be relevant at different times. This section describes the lawful basis for processing personal data and special category data at Proton Partners International Limited.

Contract

When you contact us and ask us for information with a view to receiving services from us, supplying services to us, entering into investments or collaboration opportunities,  we process your personal data to meet those requests.

We therefore rely on this lawful basis for processing:

The processing is necessary for a contract you have with the individual, or because they have asked you to take specific steps before entering into a contract’.

Legal obligations

We are subject to a range of legal obligations in relation to the services we provide. These may range from our requirements under the UK Companies Act, employment law, tax purposes and regulatory requirements laid down in healthcare legislation.

We therefore rely on the following lawful purpose:

’Processing is necessary for compliance with a legal obligation to which the controller is subject.’

Legitimate interests

The term ‘legitimate interests’ relate to our normal business activities which we carry out, and which would reasonably be expected as part of the running of our business and which does not impact your rights, freedoms or interests.

When you contact us to enquire about services, opportunities for investment, collaboration, providing services to us, receiving services from us or working for us, we process your personal data in order for us to respond to you and provide you with the required information and services.

Data protection legislation requires that any processing must be ‘necessary’ and on all occasions we must balance our interests as a company against those of the individual’s. If the individual would not reasonably expect the processing, or if it would cause unjustified harm, their interests are likely to override our legitimate interests. We will always ensure that our legitimate interests do not cause unjustified harm to you.

Our company’s aim is to deliver diagnostics, planning, treatment and research in the field of oncology and therefore personal data is collected and processed to achieve this aim.

We therefore rely on the following lawful purpose:

‘The processing is necessary for your legitimate interests or the legitimate interests of a third party unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests.’

Special Category Data

In the planning and delivery of our services, it is necessary for us to process special category data in relation to responding to enquires you make about treatments and services, providing services to you, for undertaking our responsibilities in overseeing governance in our Rutherford Cancer Centres and in relation to processing employee data.

The lawful process by which we are able to process special category data is as follows:

‘Processing is necessary for the purposes of preventive or occupational medicine, for the assessment of the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services on the basis of Union or Member State law or pursuant to contract with a health professional and subject to the conditions and safeguards referred to in paragraph 3.’

There may be situations where complaints or claims are made against us a company or against our independent medical practitioners and where the processing of special category data is necessary to respond to those complaints or claims.

The lawful purpose we would reply on for special category data in these circumstances is as follows:

Processing is necessary for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity.’

Consent

We will always ask for your consent to send you information on our services and treatment and business opportunities. You can opt in to receiving information when you complete our on line forms or are provided with opportunities to join mailing lists at our events

There may be other circumstances where we require your consent. Wherever the processing of your personal data requires consent we will ensure we provide you with full information to allow you to make an informed decision:

‘The individual has given clear consent for you to process their personal data for a specific purpose.’

Who your information is shared with

Third Parties

Within the day to day running of our business, we may use third party organisations to support the essential delivery of services. These may be; IT service providers, financial advisors, storage & shredding companies, debt management companies. We may also be required to share personal information to prevent fraud and to assist the police in the prevention and detection of a crime.

Where third party organisations are used, who may have access to your personal data, we ensure that a contract is in place, security checks are undertaken and that we have a lawful basis for sharing the personal data.

Internal

Personal data may be shared between Company subsidiaries and PPI in order for PPI to carry out its functions of ‘parent’ company. Such processing may involve the provision of IT storage systems, mailing lists, contact databases and the undertaking and reviewing of financial transactions,

International Transfers

Where we, or third party companies who we engage with, ‘process’ data (transfer, store) outside of the European Economic Area ("EEA") we ensure that appropriate security checks are undertaken and that processing is in line with the data protection legislation.

Where data is processed outside of the EEA, it will be processed by staff operating outside the EEA who work for us or for third party companies engaged by us.

How we protect the security and confidentiality of your personal data

All employees are bound by contractual confidentiality clauses in employment contracts, receive mandatory training in data protection and confidentiality and process information under the direction of mandatory policies and procedures. Audits are carried out to ensure information recorded and created is accurate, up to date and kept securely.

Marketing

We would like to keep you updated on the services and treatments that we provide but will only do this where you have opted in to receive such updates. When you access our services you are provided with an option to join our mailing list. You may also have the opportunity to opt in through links or forms when you visit our website or by completing forms when you attend events. When you opt in to receive information on our services, should you wish to stop receiving updates you can contact us and we will remove you from any mailing lists.

We never share or sell your data to external marketing companies.

Your rights under data protection legislation

The right to be informed

You have the right to be informed of how we process your personal data. We inform you of how we process your data, through the provision of this Privacy Notice, and in notices we provide when you register for our services. We also inform you of other types of processing such as call recording or CCTV through notices and recorded messages. You can also contact us at any time to query any aspect of the processing of your data.

The right to access your personal information

You may contact us to request details of the type of processing we carry out on your personal data and a copy of the personal information which we hold about you. This is known as a Subject Access Request and must be submitted in writing to to the Data Protection Officer at the address shown below.

We must process your request within one month of receipt of the request, however, if it is a complex request we may need to extend this by up to two months. You will be kept informed if an extension is required.

The right to rectification

You have the right to have incorrect personal information amended or completed if it is incomplete.

The right to erasure

You have the right to request that we delete the personal information we hold about you. However, there are exceptions to this and in certain circumstances we may not be able to comply with your request. For example, the right of erasure of personal information does not apply to special category data where it is being processed for medical diagnosis and the provision of health and social care.

The right to restrict processing

You have the right to limit the way we use your personal information in certain circumstances. For example, this may occur if:

  • you have asked us to amend inaccurate information or
  • you feel that your information has been unlawfully processed

The right to data portability

Where we are processing personal data purely in electronic format, there may be circumstances where you can request to have your data transferred (if technically possible) to another individual or organisation of your choice in an electronic format.

The right to object

You have the right to object to the processing of your personal data in certain circumstances:

Direct Marketing:

You can ask us to stop processing your personal data for direct marketing at any time. When we receive an objection to processing for direct marketing we must stop processing your data for this purpose.

Legitimate Interests

You have the right to object to us processing your personal data for our legitimate interests (i.e. our business reasons) however you must give specific reasons to why you are objecting. We may not be able to meet your request depending on the reasons stated.

Automatic decision-making and profiling 

We do not use automated decision-making tools or profiling when you provide us with personal information.

Personal data collected when using our website 

When you visit our website, we automatically collect the following information:

  • Technical information, including the Internet protocol (IP) address used to connect your computer to the internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform
  • Information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page

Tracking Performance of our Website – Use of Cookies

The website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. By continuing to browse the site, you are agreeing to our use of cookies.

We use Google Analytics cookies to collect information about how visitors use our site. Cookies are small files which are stored on a user’s computer, designed to hold a small amount of data specific to a particular user and website. Using cookies allows us to collect information about how visitors use our website.

Google Analytics sets four types of first-party cookies automatically:

  • _utma
  • _utmb
  • _utmc
  • _utmz

These cookies track the number of visitors to our website, how long the website sessions last, and note where the website visitor arrived from. The information collected by these cookies is anonymised and visitors cannot be identified. We will use this information to write reports and make improvements to the website.

You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.

How long do we keep personal data for?

Under data protection legislation personal data must only be processed for as long as it is necessary and not kept for an excessive period of time. How long we keep your personal data will depend on our relationship with you (i.e. the purpose for which we have obtained your personal data).

We retain personal data to provide our services, stay in contact with you and to comply with applicable laws, regulations and professional obligations that we are subject to.

Where personal data is received as part of a contract, clauses within the contract will specify the retention period and return or deletion of personal data as relevant to each contract.

How to contact us 

You can contact the Data Protection Officer by writing to us at:

The Data Protection Officer

The Rutherford Cancer Centres Limited

Celtic Springs

Spooner Close

Newport

NP10 8FZ

How to complain

If you believe that your information has been unfairly or unlawfully used, you have the right to contact the Information Commissioner’s Office at the address below:

Information Commissioner's Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Tel: 0303 123 1113 (local rate) or 01625 545 745

This Privacy Notice was updated on 24th May 2018