Privacy Policy

Welcome to Clinical Coding Hub and our website at www.clinicalcodinghub.co.uk. This Privacy Policy explains our practices for collecting, using, protecting and disclosing the Personal Data we collect from you when you visit our website and use our services.

General Information

What law applies?

In principle, we will only use your Personal Data in accordance with the applicable data protection laws, in particular the UK`s Data Protection Act (“DPA”) and the EU`s counterpart the General Data Protection Regulation (“GDPR”).

What is Personal Data?

Personal Data is any information relating to personal or material circumstances that relates to an identified or identifiable individual. This includes, for example, your name, date of birth, e-mail address, postal address, or telephone number as well as online identifiers such as your IP address.

What is processing?

“Processing” means any operation or set of operations which is performed upon Personal Data, whether or not by automatic means. The term is broad and covers virtually any handling of data.

Who is responsible for data processing?

The responsible party within the meaning of the DPA and the GDPR is Clinical Coding Hub Limited of 60 Simpson Close, Leagrave, Luton, Bedfordshire, England, LU4 9TP, UK (“Clinical Coding Hub”, “we”, “us”, or “our”).

If you have any questions about this policy or our data protection practices, please email us at info@clinicalcodinghub.co.uk, use our Contact Form or write to us at the above address.

What are the legal bases of processing?

In accordance with the DPA and GDPR, we have to have at least one of the following legal bases to process your Personal Data:

  • Consent – This is where we have asked you to provide explicit permission to process your data for a particular purpose.
  • Contract – This is where we process your information to fulfil a contractual arrangement we have made with you or reply to your messages, e-mails, posts, calls, etc.
  • Legitimate Interests – This is where we rely on our interests as a reason for processing, generally this is to provide you with the best products and service in the most secure and appropriate way. Of course, before relying on any of those legitimate interests we balance them against your interests and make sure they are compelling enough and will not cause any unwarranted harm.
  • Legal Obligation – This is where we have a statutory or other legal obligation to process the information, such as for archiving or the investigation of crime.

Data we collect automatically

Log data

Even if you do not log in or register on our website, but simply browse our website, data is collected and stored and processed by us. Specifically, this requires the IP address of your computer, Date and time of access, Name and URL of the accessed file, Browser used, Number of bytes transferred, Status of the page retrieval, Session ID, Referrer URL.

Hosting

To provide our website, we use the services of Siteground Ltd who process all data to be processed in connection with the operation of our website on our behalf. The legal basis for the data processing is our legitimate interest in providing our website.

Content Delivery Network

We use the Content Delivery Network (CDN) of WordPress by Automattic Inc to distribute our online content. A CDN is a network of regionally distributed servers of our technical service providers connected via the Internet. When our website is visited, your device`s browser transmits information to these service providers, which is collected in corresponding server log files. Server log files are generally anonymised and then transmitted without any personal reference. Server log files however include, besides technical information, device information and the IP address of the visiting device. The legal basis for processing is our legitimate interest.

Content Management System

We also use the Content Management System (CMS) of WordPress to publish and maintain the created and edited content and texts on our website. This means that all content and texts submitted to us is transferred to WordPress. This represents a legitimate interest.

Third-party services and content

We use content or service offers of third-party providers on the basis of our legitimate interests in order to integrate their content and services (“services”).

This always requires that the third-party providers of this content are aware of the IP address of the user, as without the IP address they would not be able to send the content to their browser. The IP address is therefore necessary for the display of this content.

The following provides an overview of third-party providers and their content, together with links to their privacy policies, which contain further information on the processing of data and so-called opt-out measures, if any,

Cookies

We use so-called cookies on our website. Cookies are pieces of information that are transmitted from our web server or third-party web servers to your web browser and stored there for later retrieval. Cookies may be small files or other types of information storage. There are different types of cookies:i)Essential Cookies. Essential cookies are cookies to provide a correct and user-friendly website; and ii) Non-essential Cookies. Non-essential Cookies are any cookies that do not fall within the definition of essential cookies, such as cookies used to analyse your behaviour on a website (“analytical” cookies) or cookies used to display advertisements to you (“advertising” cookies).

As set out in the UK`s Privacy and Electronic Communications Regulations (“PECR”) and the EU`s Privacy and Electronic Communications Directive (“PECD”), we need to obtain consent for the use of Non-essential Cookies. For further information on the cookies we use, please refer to our Cookie Policy. The legal basis for processing is our legitimate interest and your consent.

Cookie consent

Our website uses a so-called cookie consent tool to obtain your consent to the storage of cookies and to document this consent. When you enter our website, the following Personal Data is processed by us: a) Your consent(s) or revocation of your consent(s); b) Your IP address; c) Information about your browser; d) Information about your device; d) Time of your visit to the website. The basis for processing is our legitimate interest and your consent.

Data we collect directly

Contacting us

You can easily contact us via our contact form, e-mail or social-media. In this case, we store and process the following data from you: Name, e-mail address, telephone number as well as other personal data that you provide when contacting us. This data is collected and processed exclusively for the purpose of contacting you and processing your request and then deleted, provided there is no legal obligation to retain it. The legal bases for processing are contract and our legitimate interest.

We are present on social media (currently Instagram, Facebook, LinkedIn and YouTube). If you contact or connect with us via social media platforms, we and the relevant social media platform are jointly responsible for the processing of your data and enter into a so-called joint controller agreement. The legal basis is our legitimate interest, your consent or, in some cases, the initiation of a contract.

User account

To use our services, you can register and log in. Here, too, we store data in order to create a User account for you: Nickname, E-mail address, chosen password. We store this data as long as you are registered with us. If you delete your account, we will delete your data unless there is a legal retention period on our part. In this case, we must store your data for longer. The legal bases for processing are your consent, the provision of our contractual services and our legitimate interest.

Membership

We process your first name, last name, e-mail address, and billing address, and the data related to your contract with us data to handle the contractual relationship between you and us. The legal basis for the data processing is contract.

Payment Data

If you make a purchase your payment will be processed via our payment service providers PayPal and Stripe. Payment data will solely be processed through PayPal or Stripe and we have no access to any Payment Data you may submit. The legal basis for the provision of a payment system is the establishment and implementation of the contract.

Data management and customer support

For optimal customer support, we store your first name, last name, e-mail address, and the data related to your contract with us on our website and or our customer relationship management system provided by FluentCRM (WpManageNinja LLC). This data processing is based on our legitimate interest in providing our customer service.

Marketing

Insofar as you have given us your separate consent to process your data for marketing and advertising purposes, we are entitled to contact you for these purposes via the communication channels you have given your consent to.

You may give us your consent in a number of ways including by selecting a box on a form where we seek your permission to send you marketing information, or sometimes your consent is implied from your interactions or contractual relationship with us. Where your consent is implied, it is on the basis that you would have a reasonable expectation of receiving a marketing communication based on your interactions or contractual relationship with us.

Direct Marketing generally takes the form of e-mail but may also include other less traditional or emerging channels. These forms of contact will be managed by us, or by our contracted service providers. Every directly addressed marketing sent or made by us or on our behalf will include a means by which you may unsubscribe or opt out.

Administration, financial accounting, office organization, contact management.

We process data in the context of administrative tasks and the organization of our business and compliance with legal obligations, such as archiving. In this context, we process the same data that we process in the provision of our contractual services. The processing bases are our legal obligations and our legitimate interest.

Our employees will also have access to data that you knowingly share with us for technical support or to import data into our services. We communicate our privacy and security guidelines to our employees and enforce privacy safeguards strictly.

Principles of processing Personal Data

Storage and Retention

As far as necessary, we process and store your personal data for the duration of our business relationship, which also includes, for example, the initiation and execution of a contract.

In addition, we are subject to various storage and documentation obligations, which result from the minimum statutory retention periods and HMRC, among others. The retention and documentation periods specified there are two to six years.

Security

Our website uses SSL or TLS encryption to ensure the security of data processing and to protect the transmission of confidential content, such as orders, login data or contact requests that you send to us. We have also implemented numerous security measures (“technical and organisational measures”) for example encryption or need to know access, to ensure the most complete protection of Personal Data processed through this website.

Nevertheless, internet-based data transmissions can always have security gaps, so that absolute protection cannot be guaranteed. And databases or data sets that include Personal Data may be breached inadvertently or through wrongful intrusion. Upon becoming aware of a data breach, we will notify all affected individuals whose Personal Data may have been compromised as expeditiously as possible after which the breach was discovered.

Special Category Data

Unless specifically required when using our services and explicit consent is obtained for that service, we do not process special category data.

Automated decision-making

Automated decision-making is the process of making a decision by automated means without any human involvement. Automated decision-making including profiling does not take place.

Do Not Sell

We do not sell your Personal Data.

Sharing and Disclosure

We will not disclose or otherwise distribute your Personal Data to third parties unless this is i) necessary for the performance of our services and, ii) you have consented to the disclosure, iii) or if we are legally obliged to do so e.g., by court order or if this is necessary to support criminal or legal investigations or other legal investigations or other legal proceedings; or proceedings at home or abroad or to fulfil our legitimate interests.

International Transfer

We may transfer your Personal Data to other companies as necessary for the purposes described in this Privacy Policy. In order to provide adequate protection for your Personal Data when it is transferred, we have contractual arrangements regarding such transfers. We take all reasonable technical and organisational measures to protect the Personal Data we transfer.

Your Rights and Privileges

Privacy rights

Under the DPA and the GDPR, you can exercise the following rights:

  • Right to information
  • Right to rectification
  • Right to deletion
  • Right to data portability
  • Right of objection
  • Right to withdraw consent
  • Right to complain to a supervisory authority
  • Right not to be subject to a decision based solely on automated processing.

If you have any questions about the nature of the Personal Data we hold about you, or if you wish to exercise any of your rights, please contact us.

Updating your information

If you believe that the information we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion, or object to its processing, please do so by contacting us.

Withdrawing your consent

You can revoke consents you have given at any time by contacting us. The legality of the data processing carried out until the revocation remains unaffected by the revocation.

Access Request

In the event that you wish to make a Data Subject Access Request, you may inform us in writing of the same. We will respond to requests regarding access and correction as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days, we will tell you why and when we will be able to respond to your request. If we are unable to provide you with any Personal Data or to make a correction requested by you, we will tell you why.

Complaint to a supervisory authority

You have the right to complain about our processing of Personal Data to a supervisory authority responsible for data protection. The supervisory authority in the UK is: The Information Commissioner’s Office (ICO) is located at Wycliffe House, Water Ln, Wilmslow SK9 5AF, UK www.ico.org.uk

Changes

We may update this Privacy Policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons.

Contact us

For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us using the details provided above.

Effective Date

Thursday, 25 May, 2023