LEGITIMATE INTERESTS ASSESSMENT for SpecialistInfo

SpecialistInfo has undertaken a Legitimate Interests Assessment and this is documented below. The Assessment conforms to the Guidance for Legitimate Interest Assessments provided by the Information Commissioner's Office ('ICO').
See ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/lawful-basis-for-processing/legitimate-interests/


IDENTIFYING A LEGITIMATE INTEREST
Question Answer
Why do you want to process the data - what are you trying to achieve? To provide an Internet based service ('the Service') for healthcare professionals (including Consultants, GPs and their Secretarial Staff) and those who need to work with healthcare professionals for healthcare purposes that enables them to identify, locate and contact appropriate Consultants, GPs, GP Practice Managers and Nurses and CCG staff according to (as applicable) their qualifications, location, speciality, special interests and other information supplied by the doctors and others concerned.

Who benefits from the processing? In what way? Two groups - 1) The data subjects themselves (Consultants, GPs, their secretaries and Practice Staff, Nurses and CCG Staff) and 2) those healthcare professionals who need to contact the data subjects for professional healthcare purposes.

Are there any wider public benefits to the processing? Yes, the service is available to patients, both NHS and Private, who may use the Service to identify a conveniently located doctor with relevant expertise. The service also helps 1) pharmaceutical and medical device companies to find Specialists or GPs interested in clinical trials and research and 2) law firms and insurance companies to find doctors to act as expert witnesses in medico-legal claims.

How important are those benefits? Very important for helping patients, researchers, personal injury and clinical negligence claimants and healthcare professionals.

What would the impact be if you couldn't go ahead? The service would cease to the detriment of all concerned.

Would your use of the data be unethical or unlawful in any way? No.

THE NECESSITY TEST
Does this processing actually help to further that interest? Yes, the processing is an integral part of the service.

Is it a reasonable way to go about it? Yes, the service uses Information Technology and the Internet for communicating with data subjects to obtain their up to date details and provide the service efficiently and cost-effectively to users for healthcare related purposes.

Is there another less intrusive way to achieve the same result? Intrusion to data subjects is minimal and makes use of email, telephone, fax and postal methods of communication with data subjects. As a considerable number of healthcare organisations use the service, there is less intrusion to data subjects as they supply the data once for use by many different healthcare users who would otherwise have to contact the data subjects individually themselves. This would be considerably more intrusive.

THE BALANCING TEST
What is the nature of your relationship with the individual? SpecialistInfo is independent from both the users of the service and the data subjects. One of the founders is a doctor.

Is any of the data particularly sensitive or private? No. It mainly consists of names, work contact details (telephone, fax, email and postal addresses), qualifications, where and when qualified, specialty and special interests.

Would people expect you to use their data in this way? As doctors, practice staff, nurses and CCG staff, the data subjects will expect their identity, location, qualifications, experience and areas of expertise to be made available to other healthcare professionals.

Are you happy to explain it to them? Yes. Data subjects are regularly contacted to inform them of the existing details held processed, to enable them to update these details where necessary and to re-iterate the use to which the details are put in the service.

Are some people likely to object or find it intrusive? Inevitably but experience has shown this to be a very small number (< 0.1%)

What is the possible impact on the individual? Minimal. Regular contact more with data subjects by email, telephone, fax and post is normally twice per year.

Are any of the individuals vulnerable in any other way? No.

Can you adopt any safeguards to minimise the impact? Yes. Details of contact dates and response dates are stored to avoid repetition of contact and deletions are marked as such to avoid contact again through subsequent research.

Can you offer an opt-out? Yes, if the data subject has good reasons and the extent of data can be reduced on request for good reasons. Removal from the service is avoided where possible as it could imply erroneously that the data subject was no longer practising.

OUTCOME OF ASSESSMENT
The above assessment shows that the Service is of considerable benefit not only to the Controller but also to the Data Subjects concerned (consisting of Consultants, GPs, Practice Managers, Nurses and CCG Staff) in assisting them to provide their experience and expertise to the healthcare industry, medico-legal claimants and patients. The inclusion of Data Subjects in the Service may result in Data Subjects receiving postal, telephonic, fax or email (where they have provided it) communications from the Controller. Communications may also be received from users of the Service on a healthcare related topic. Users will normally use the location, specialty and special interests data provided by the Service to communicate with Data Subjects likely to be interested in the topic concerned. If the topic is of no interest to the Data Subject, it is easy to dispose of, or delete, the communication concerned. This minor inconvenience, which can easily be delegated to secretarial staff, is insignificant compared to the potential benefits of the Service to a) Data Subjects themselves by promoting their experience, expertise and interests to healthcare organisations, medico-legal claimants and patients and b) users of the Service for healthcare related purposes.

Signed:

Dr Michael Scatchard MBCh MRCGP

Position: Director

Review Date: 27 April 2018

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