Privacy Policy

Privacy Policy 

Pulse OH Ltd has appointed Heather Colthart as Data Protection Officer. Our Registered Business address is 3 East Cliff Gardens, Folkestone, CT16 6AR.

This policy is for people that we hold information on or are about to hold information on. Pulse OH Ltd is committed to ensuring we hold your data securely as this policy explains:

Pulse OH Ltd holds “Personal and Special Information” as defined by the GDPR and Data Protection Regulations. We treat our responsibilities very seriously as an organisation and as individuals we will always treat your information as important and ensure that we protect its use, access, and accuracy. Pulse OH Ltd is registered with the Information Commissioners Office. Registration Number: ZB334512 

Pulse OH Ltd employs specialist clinicians who provide advice and medical treatment. These include doctors, and specialist nurses. 

We hold employee’s occupational health records which are medical and personal records that must be held for safety and wellbeing at work. Authorised medical professionals may only hold occupational health records as set out in the Data Protection Act (2018) s(204). 

We process your data for this purpose in compliance with the Data Protection Act (2018) Schedule 1 Part 1 S(2)

Health or social care purposes.

2 (1) This condition is met if the processing is necessary for health or social care purposes.

2 (2) In this paragraph “health or social care purposes” means the purposes of.

· preventive or occupational medicine

· the assessment of the working capacity of an employee

· medical diagnosis

· the provision of health care or treatment

· the provision of social care

· the management of health care systems or services or social care systems or services

Where we provide occupational health services and/or Employee Assistance Programme (EAP) services, we will hold information about employees and this will include personal details such as name, home address, date of birth, job details and medical records. We need this information to be able to provide accurate advice to employees and employers ensuring that work does not damage employee health and employees are fit for the work they are employed to do. 

Pulse OH Ltd use the information held in the delivery of our services. 

We need personal information such as name, address and date of birth in order to identify and verify the correct person and in some cases where we need to communicate with a health care provider this is the standard identification information used by the NHS.

We need personal contact details such as telephone number and email address to assist us communicating with employees and employers when booking appointments.

We need and will create medically confidential information so that our clinicians can provide professional advice based on health fitness and wellbeing.

We may retain telephone recordings and this data would be held for the training and monitoring purposes of our colleagues and employees. Any voice recording is destroyed after 31 days and does not form part of medical records. 

All medical information is held securely and can only be accessed by Pulse OH Ltd employees. 

We do not and will never sell information to anyone else.

We do not share information with anyone else other than employers with employee consent and we will always obtain employee consent before we provide information. 

We will not use information to sell anything or promote any services that are not related to the provision of occupational health. 

Most of the information we hold is electronic, in some limited cases we do still hold paper records. Our computer servers are located within the UK/EU.

When a company becomes a client of Pulse OH Ltd the historical occupational health records held by the previous occupational health provider are transferred to Pulse OH Ltd. Employees will have been consulted on this transfer. During the time that Pulse OH Ltd provides a company with occupational health services we will create and add our records to an employee’s occupational health file. If a company leaves Pulse OH Ltd occupational health files will be transferred to a new occupational health provider, and employees should be consulted on that change at that time. Pulse OH Ltd will not retain a copy of employee records once the records have been transferred. 

Medical Reports

Pulse OH Ltd clinicians may require medical reports from healthcare professionals such as a GP or Specialist Consultant. If medical records are required from healthcare professionals involved, we will always obtain written consent from the employee before requesting the information. The employee will be informed of the following:

· The reason why the report is needed.

· Their rights under the Access to Medical Reports Act (1988)

· Their right to see a copy of the report being sent to Pulse OH Ltd 

A report will be written to an employer based on the medical report sent to Pulse OH Ltd. It will not be the actual report that a healthcare provider sends to us.

How an employee can see an occupational health report that Pulse OH Ltd sends to an employer

Where Pulse OH Ltd sends a report to an employer, if the report is being written by an Occupational Health Physician (OHP) (Doctor) or Occupational health Advisor (OHA) (nurse) the employee will have the opportunity to see the report before it is sent to their employer. Reports are only sent to employees via secure email procedures. 

Data Retention

Occupational health records are held on behalf of an employer and will be stored in line with their data retention policy and the relevant UK law. Employees can contact their employer to confirm their data retention policy. Occupational health records will be kept whilst employees are employed by their employer and retained until they leave, after which there are legal time frames that an employer needs to retain employee records.  In all other cases Pulse OH Ltd Data Retention Policy is:

Reason to retain records

Time Period

- Telephone voice recordings – when used - 31 Days

- Employee Liability Claims - 3 Years

- Limitation Act Claims - 6 years

- Industrial Disease Records - 40 years

- Rail Workers Sentinel Medicals & drug and alcohol testing - 10 years 

Cookies 

Our website may use cookies to better the overall experience of our users. In accordance with legislation and where necessary, our website ensures the user can accept and disable the use of cookies.

Cookies are used:

· to provide a more interactive and personal user experience

· for statistical purposes

· to show adverts that may be of interest in and control the number of times they are seen

It is important to note that disabling cookies may have a negative impact on how a site runs. Third-party companies that are providing a service for us or our website may use cookies, and these may be stored on your computer when you visit our website.

Social media Profiles

We may use social media channels. We advise our users to verify the legitimacy of any profile pertaining to be our company before interacting with them. Our social media profiles will never ask for user passwords or personal details. The social media businesses that we interact with include Facebook, Instagram, Twitter, and LinkedIn.

External Web Links

Our website contains links to external websites. We are not responsible for the privacy practices or the content on these sites. Our users are encouraged to be aware that when they leave our website, they should read the privacy policy and spam policies of each website that collects personal data. This Privacy Policy applies only to the information collected by us.

Spam Policy 

We only contact you if you have requested information or we need to update you on services we provide, or you have requested information on. 

Other privacy information.

We will regularly review this policy and any changes made will be effective immediately. Our customers, partners, colleagues, and suppliers are bound to our Privacy Policy.

Legal Information

The UK Data Protection Regulations are specific about the treatment of personal and special data. Employees have the right to receive a copy of their records by making a Subject Access Request in writing. To request a copy of data please submit your request to:

The Data Controller

Pulse OH Ltd

3 East Cliff Gardens

Folkstone

CT19 6AR

Should you have any need to complain about our services please email enquire@pulseoh.co.uk

Any complaints or praise can be sent to Heather Colthart. If you are unhappy at how Pulse OH Ltd have processed your data you can contact the Information Commissioners Office at www.ico.org.uk or write to Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5A