We collect, use and are responsible for certain personal information about you. When we do so we are subject to the General Data Protection Regulation, which applies across the European Union (including in the United Kingdom), the Privacy and Electronic Communications Regulations (PECR) and the Data Protection Act. We are responsible as ‘controller’ of that personal information for the purposes of those laws.
Personal information we collect about you
We may collect and use the following personal information about you:
- your name and contact information, including postal address, email address and telephone number;
- information to enable us to check and verify your identity, e.g. your date of birth, scanned images of your exemption certificates, driving licence or passport;
- your gender information;
- your NHS number;
- information about your medicines, and the medicines you have been prescribed currently and in the past;
- your billing information, transaction and payment card information;
- your contact history, purchase history and saved items;
- information about how you use our website, information technology (IT), communication and other systems; and
- your responses to surveys, competitions and promotions.
Personal information is required to provide our services to you. If you do not provide personal information we ask for, it may delay or prevent us from providing services to you.
How your personal information is collected
We collect most of this personal information directly from you—in person, by telephone, text or email and/or via our website and apps. However, we may also collect information:
- from a third party with your consent, e.g. your General Practitioner or the NHS Spine system, which is the main database of your medical history with the NHS;
- via our IT systems, e.g. automated monitoring of our websites and other technical systems, such as our computer networks and connections.
How and why we use your personal information
Under data protection laws, we can only use your personal information if we have a proper reason for doing so, e.g.:
- to comply with our legal and regulatory obligations;
- for the performance of our contract with you or to take steps at your request before entering into a contract;
- for our legitimate interests or those of a third party; or
- where you have given consent.
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
The table below explains what we use (process) your personal information for and our reasons for doing so:
When you register with Phlo, request that your password is reset, request that we fulfil your prescriptions or when you place an order for your prescription, we will send notifcation emails to your registered email address to fulfil our service obligations.
When you place an order for your prescription, you will also receive email notifications about its delivery from our partner, Gophyr.
Special Category Personal Data
"Special categories" of particularly sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data.
We will collect information about your health, including any medical condition, medication or health and / or sickness records. This data is special category data.
Special protection is given to this special category personal data. We use this special category personal data primarily to comply with our legal obligations (including verifying your identity and ensuring that the correct medicines are dispensed to you).
We handle your special category data with extra care. For example, we will not provide special category data to our delivery drivers.
We may use your personal information to send you updates by email about our services, including exclusive offers, promotions or new services.
We have a legitimate interest in processing your personal information for operational purposes.
We request your consent by accepting our cookie notices and if a registered customer, using our consent management system, for us to process your data for statistical, analytical, marketing and promotional purposes (see above ‘How and why we use your personal information’).
You have the right to opt out of receiving promotional communications at any time by:
- contacting us at [email protected]
We may ask you to confirm or update your marketing preferences if you instruct us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.
Who we share your personal information with
We routinely share personal information with:
- Third parties we use to help deliver your orders to you, e.g. our payment service provider and delivery company;
- Our payment services provider, WorldPay, operates as three companies:
- Worldpay (UK) Limited, The Walbrook Building, 25 Walbrook, London EC4N 8AF, United Kingdom.
- Worldpay Limited, The Walbrook Building, 25 Walbrook, London EC4N 8AF, United Kingdom.
- Worldpay AP Limited, The Walbrook Building, 25 Walbrook, London EC4N 8AF, United Kingdom.
- Our delivery partner is Gophr Ltd, PO Box 501, The Nexus Building Broadway, Letchworth Garden City, Herfordshire, SG6 9BL.
Other third parties we use to help us run our business, e.g. website hosts, network partners and marketing partners:
- Our marketing web site and newsletter subscription database is hosted by Webflow Inc, 398 11th Street, 2nd Floor, San Francisco, CA 94103.
- Our application services are hosted on Google Cloud Platform operated by Google Ireland Limited, with offices at Gordon House, Barrow Street, Dublin 4, Ireland.
- We use CloudFlare services operated by Cloudflare, Inc., located at 101 Townsend St., San Francisco, California 94107 to route network traffic.
- We use Postmark operated by WildBit, 225 Chestnut Street, Philadelphia, PA, 19106 to send transactional emails.
- We use marketing services provided by Facebook at 4-5 Grand Canal Quay Square, Dublin 2, Ireland.
- We use cookie management services provided by Cookiebot, a trading name for Cybot A/S, Havnegade 39, 1058 Copenhagen, Denmark.
- We use Intercom operated by Intercom R&D Unlimited Company, 2nd Floor, Stephen Court, 18-21 St. Stephen's Green, Dublin 2, Republic of Ireland, to provide real-time messaging services.
- We use a Patient Medication Record system provided by Clanwilliam Health (UK), Aurora House, Deltic Avenue, Rooksley, Milton Keynes, MK13 8LW, United Kingdom. System and patient data resides in two locations (1) Phlo's London Pharmacy Hub at Containerville, Unit 13, 35 Corbridge Crescent, London, E2 9EZ and (2) data centres in the Republic of Ireland operated by Amazon Web Services, One Burlington Plaza, Burlington Road, Dublin 4, Ireland.
- Third parties approved by you, e.g. third party payment providers such as your bank, which may request that you approve a payment to us.
- Our financial transaction management host, Xero (UK) Ltd, Bank House, 171 Midsummer Boulevard, Milton Keynes, MK9 1EB and our bank, Shawbrook Bank, Lutea House, Warley Hill Business Park, The Drive, Great Warley, Brentwood, Essex CM13 3BE.
- Our financial accountants, Johnston Carmichael, 227 W George St, Glasgow G2 2ND.
- Our regulators, the General Pharmaceutical Council and the Information Commissioners Office.
- The NHS, which holds your personal data, prescription records and your Summary Care Record. We request approval from your General Practitioner service for prescription requests you make and we pass on information you may provide to us about your requirements.
We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers to ensure they can only use your personal information to provide services to us and to you. We may also share personal information with external auditors, e.g. in relation to ISO or Investors in People accreditation processes and the audit of our accounts.
We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
The data that we collect from you through our applications and systems can help others. We want to share patterns of information on what medicines people take, when, where and for how long. The way in which we do this is by collating data, then removing personal information (names, postal addresses, email addresses, NHS numbers). We analyse the remaining data to identify insights and behaviours so that we can contribute with others to the development of medicines and how treatments are marketed and made available to people. This data can be sold to or shared with to government departments, healthcare professional bodies, the pharmaceutical industry and organisations who want to understand how medicines are used in the real world. Using our consent management functionality, you can tell us that you are comfortable with your medical data being used this way.
We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually, personal information will be redacted but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
Where your personal information is held
Information may be held at our offices and those of our pharmacy, third party system provers and agencies, service providers, representatives and agents as described above (see above: ‘Who we share your personal information with’). Your data is hosted in our pharmacy premises and offices in the United Kingdom and at data centre facilities in the Republic of Ireland, except for Intercom, Webflow and Postmark services, which are hosted in the United States of America under the EU-US Privacy Shield framework.
How long your personal information will be kept
We will keep your personal information while you have an account with us or we are providing services to you. Thereafter, we will retain your personal information:
- to respond to any questions, complaints or claims made by you or on your behalf;
- to show that we treated you fairly; and
- to keep records required by law.
We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information.
To navigate data retention requires us to define the roles people can have when using Phlo’s applications and systems. We call these Data Subjects:
PhloApp Users: people who have begun Phlo’s application registration process but not completed it.
PhloApp Customers: people who have completed Phlo’s application registration process. Customers can be thought of as fully registered Users.
- Active Customers: people who are customers and used the Phlo service at least once in the last 365 days.
- Lapsed Customers: people who have not logged into their Phlo account for more than 730 days or have not opened a marketing email in the same timescale.
Workphlo Users: Phlo employees or contractors who have logged into the WorkPhlo application.
Phlo’s required retention periods across its systems are:
Data retention periods are enforced using a combination of automated housekeeping jobs with manual oversight. Transactional data, such as prescription orders and financial payment records, will be retained for as long as needed.
You have the following rights, which you can exercise free of charge:
For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.
If you would like to exercise any of those rights, please:
- email, call or write to us - see below: ‘How to contact us’; and
- let us have enough information to identify you (eg your full name, address and user or reference number);
- let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and
- let us know what right you want to exercise and the information to which your request relates.
Keeping your personal information secure
We have appropriate security measures to prevent personal information from being accidentally lost or used or accessed unlawfully. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
How to complain
We hope that we can resolve any query or concern you may raise about our use of your information.
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns or telephone: 0303 123 1113.
This privacy notice was published on 19th September 2019.
We may change this privacy notice from time to time. When we do we will inform you via the email address provided by you.
How to contact us
Our contact details are:
Address: Phlo Technologies Ltd, c/o Gillespie & Anderson, 147 Bath Street, Glasgow, G2 4SN.
Email: [email protected]
Telephone: 0141 255 0751