PRIVACY POLICY & DATA

Our privacy policy outlines how CTC uses and protects any information that you provide during your client journey. This notice sets out how CTC will use and protect any information that you provide when you use any aspect our service including, website and mobile applications. As a client of CTC, we hold personal information (known as “personal data”). Personal data refers to information from which you as an individual can be identified.

The information we need to hold includes:

Personal Information:

  • Name
  • Date of birth
  • Gender
  • Home Address
  • Email Address
  • Medical information
  • Personal Medical Questionnaire answers
  • Blood and Urine results
  • Research and Development testing data – Statistical analysis of medical/testing data
  • Other information relevant to client surveys and/or offers

CTC will use the information that you provide to generate a personalised health report, thus providing the service for which you have enrolled in. Additional information, including contact details, is required in setting up appointments, renewals and in case any concern is highlighted and we need to make contact with you urgently. We will retain your personal information no longer than necessary, in line with GDPR. We will not collect any personal data from you that we do not need.

Personal data relating to the well-being service is held on paper and controlled computer systems. As the “data controller”, CTC and its affiliates must process this information fairly and lawfully.

During the running of the well-being service, we also hold and process particularly sensitive information about you. This is known as “sensitive personal data” and specifically this information includes present health including medical testing carried out through our service, past medical history and where applicable family history.

CTC is not allowed to share personal data about you with other organisations or people, unless permitted by law, or you have provided consent or a third party is required to fulfil your order (in such circumstances, the third party is bound by similar data protection requirements).

We do share personal data with the following:-

  • Third Party Laboratory Services, our partnered supplier in providing the medical tests included in our service.
  • Private medical General practitioners for medical consultations.

We may share information with:-

  • CTC Laboratories for Research and Development analysis of testing to make improvements or introduce new tests however information with be anonymised (Personal Identifiable information removed).

    In cases where data is requested to be sent outside the EEA, appropriate safeguards are put into place to ensure security and protection.

We must keep all personal data safe and hold it for no longer than is necessary. To meet the requirements in the service being provided to our clients we would hold personal identifiable information for a minimum of 11 years. However, given the nature of our service, information gathered during the client’s time within our service, such as the medical questionnaire, medical results will be retained longer for research and development purposes. These purposes are for the improvement of medical tests available, for development of new novel biomarkers for CTC’s portfolio and to make available to clients.

We review the personal data held on a regular basis.

Your rights

  • You have the right to see personal identifiable data that is held about you and a right to have a copy provided to you. However, for information to be shared to someone on your behalf thorough consent must be provided by you.
  • If at any point your personal data changes it is up to you to update us.
  • You can require limit or restrict the processing of your personal data in certain circumstances, for example, whilst a complaint about it accuracy is being resolved.
  • You can object to your personal data being processed, although CTC can override this objection in specific circumstances where legal obligations object to this.
  • Where you have given us consent to process your personal data, you can withdraw that consent before the provision of your programme. However, if the service has been provided, payment for this service still needs to be made.
  • You can request that your personal data to be forgotten, this will mean your data will be removed from our marketing mailing lists and patient information system.
  • Health data is moved to further secured locations with limited access for retention for legal purposes only.
  • Anonymised (all personal identifiable information removed) data may be retained for Research and Development purpose, as mentioned.

You should be aware that taking some of the above steps will impact on the ability of CTC to complete the service you have agreed, generation of medical data or medical/scientific consultation.

All information pertaining to you, for example Personal Health Plan and/or consultations, if requested, will generally be provided free of charge, although CTC can charge a reasonable fee in certain circumstances.