Privacy Notice

Welcome to the Bridge Clinic Limited Privacy Notice. At Bridge Clinic Limited, we offer clinical experts who are transparent, honest, and empathetic in delivering fertility treatments. We aim to offer the best chances of success while reducing the mental and physical burden that patients experience while undergoing treatment.

We know that our patients often come to us at stressful and difficult times in their lives and we do everything that we can to make them feel as supported and comfortable as possible. This also means that we guard their personal data and protect their privacy. We do the same for everyone that interacts with our organisation and wants to help us in our mission.

Our Privacy Notice applies to all of our website users, prospective staff as well as prospective and existing patients, third-party suppliers and partners that engage with us. The medical sector is to do with people and trust, and we appreciate those that engage with us and trust us, and we are committed to maintaining that trust by looking after their personal data. Support our mission and bring families to life; trust us to look after you and trust us to protect your data.

This Privacy Notice is kept regularly under review and was last updated in March 2023.

1. How have we made our Privacy Notice more digestible?

As we know that legal terminology can be complicated and we want to make this Privacy Notice as informative as possible for you to understand, we’ve created a brief glossary below which explains some key data protection terms (including ones that we’ve used by capitalising the first letter in a word in this Privacy Notice).

Consent refers to when an individual gives agreement which is freely given, specific, informed and is an unambiguous indication of their wishes. It is done by a statement or by a clear positive action in respect of the Processing of any Personal Data relating to them.

Criminal Convictions Data refers to Personal Data relating to criminal convictions and offences and includes Personal Data relating to criminal allegations and proceedings.

Data Controller refers to an organisation that determines when, why and how to Process Personal Data. It is responsible for establishing policies and procedures in line with Data Protection Laws.

Data Processor refers to an organisation that Processes Personal Data on behalf of a Data Controller. It is responsible for establishing policies and procedures in line with Data Protection Laws and also its contractual obligations with Data Controllers.

Data Protection Laws refers to the UK GDPR, the Privacy and Electronic Communications (EC Directive) Regulations 2003 and any other applicable European Union legislation (such as the General Data Protection Regulation 2016/679) relating to personal data. The “UK GDPR” is the retained version of the General Data Protection Regulation 2016/679 as it forms part of the law of England and Wales, Scotland and Northern Ireland by virtue of section 3 of the European Union (Withdrawal) Act 2018 and as amended by Schedule 1 to the Data Protection, Privacy and Electronic Communications (Amendments etc) (EU Exit) Regulations 2019 (SI 2019/419). It sits alongside the Data Protection Act 2018.

European Economic Area (“EEA”) refers to the 27 countries in the European Union, Iceland, Liechtenstein and Norway.

Legitimate Interest refers to when an organisation’s interests are legitimate (as they need to do something to operate) and these interests do not override an individual’s interests or fundamental rights and freedoms.

Personal Data refers to any information identifying an individual or information relating to an individual that an organisation can identify (directly or indirectly) from that data alone or in combination with other identifiers that it Processes. Personal Data includes Special Category Personal Data, Criminal Convictions Data and pseudonymised Personal Data. Further examples of Personal Data are included in section 5 of this Privacy Notice. Personal Data excludes anonymous data or data that has had the identity of an individual permanently removed.

Process or Processing refers to any activity that involves the use of Personal Data. It includes obtaining, recording or holding the data, or carrying out any operation or set of operations on the data including organising, amending, retrieving, using, disclosing, erasing or destroying it. Processing also includes transmitting or transferring Personal Data to third parties.

Special Category Personal Data refers to information revealing racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership, physical or mental health conditions, sexual life, sexual orientation, biometric or genetic data of an individual.

2. What is Bridge Clinic Limited’s status under Data Protection Laws?

We run our business out of Bridge Clinic Limited which is incorporated in England & Wales and has the registration number of 14413844 and registered address of 1-5 Christopher Place, Chalton Street, London, England, NW1 1JF.

Data Protection Laws have created the concepts of a Data Controller and a Data Processor. Bridge Clinic Limited’s status is that of a Data Controller. To keep us (and all other organisations) in check, we are supervised by the Information Commissioner’s Office (“ICO”) which is the data protection supervisory authority in England & Wales. Our registration identification with the ICO is ZB511158.

3. Do we have a Data Protection Officer (“DPO”)?

We have completed a thorough assessment of our organisation under Data Protection Laws and have made the decision to appoint a DPO. Our DPO sits at the heart of our activity, oversees our data protection compliance program and responds to everyone that gets in touch about their personal data. Our DPO can be contacted on privacy@bridgeclinic.london.

4. What is our approach to data protection compliance?

As we believe that protecting the confidentiality and integrity of Personal Data is a critical responsibility that we must take seriously at all times, we have built a robust data protection compliance program. Our data protection compliance program includes the following:

• Governance framework.
• Record of processing of activities / data register.
• Notices, policies, procedures and plans.
• Technical security controls.
• Training and communications.

Our data protection compliance program is built on the following principles.

• Personal Data must be Processed lawfully, fairly and in a transparent manner.
• Personal Data must be collected only for specified, explicit and legitimate purposes.
• Personal data must be adequate, relevant and limited to what is necessary in relation to the purposes for which it is Processed.
• Personal Data is accurate and where necessary, kept up to date.
• Personal Data should not be kept in a form which permits identification of individuals for longer than is necessary for the purposes for which the Personal Data is Processed.
• Personal Data must be Processed in a manner that ensures its security using appropriate technical and organisational measures to protect it against unauthorised or unlawful Processing and against accidental loss, destruction or damage.

5. What types of Personal Data do we collect?

We collect, use, store and transfer different kinds of Personal Data depending on our relationship with you. In general, we collect the following types:

• Identity Data (e.g., first name, maidan name, last name, title, data of birth).
• Contact Data (e.g., phone number, email address, business address and billing address).
• Communications & Marketing Data (e.g., your preferences in respect of cookies and marketing).
• Financial Data (e.g., bank account details, value added tax numbers).
• Profile Data (e.g., information about your professional background/organisation, agreements you have entered into with us such as our terms and conditions).
• Transaction Data (e.g., invoices, payment details).
• Technical Data (e.g., internet protocol addresses, browser type and version, time zone settings and location).
• Usage Data (e.g., information about how you use our website).
• Special Category Data (e.g., information about your racial or ethnic origin, sexual orientation and mental and physical health).

We also collect, use and share “Aggregated Data” such as statistical or demographic data for other purposes including research and analysis. Aggregated Data could be derived from your Personal Data but is not considered Personal Data under Data Protection Laws as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this Privacy Notice

6. Are you a website user?

Thank you for clicking on our website to find out more. If you like what you see and want to find out more, please do get in touch as we value and appreciate when people get in touch. In addition, if you want to learn more about our services, practitioners and news, you can keep up to date by following us on LinkedIn, Facebook, Twitter and YouTube.

What do we collect? We collect Technical Data and Usage Data (for tracking purposes). We also collect Identity Data, Contact Data and Communications & Marketing Data (if you decide to get in touch with us).

How do we collect this? As you interact with our website, we automatically collect this data about you by using cookies and similar technologies (check out our Cookies Notice). We also collect this data through our direct interactions with you such as when you contact us through our website.

What’s our legal ground(s) for Processing? One or more of the following apply:

• Consent (i.e., in that you are choosing to provide us with your details so that we can contact you).
• Legitimate Interests (i.e., its necessary for our Legitimate Interests in running and developing our business including our marketing strategy).
• Legal obligation (i.e., its necessary for us to comply with a legal obligation such as in the instance where you no longer wish to be contacted for direct marketing purposes).

7. Are you an applicant that has applied for a job with us?

Thank you for considering us as a potential workplace. As we grow and further develop Bridge Clinic Limited, we are keen for skilled professionals with empathy and kindness to join us on our mission.

What do we collect? We collect Technical Data and Usage Data (for tracking purposes). We collect Communications & Marketing Data. We also collect Identity Data, Contact Data and Profile Data (for when you submit your application to join us). We collect some Special Category Personal Data about you (such as information about your health where you are an applicant, and we are required to put in place reasonable adjustment for your interview). We only collect this type of Personal Data when we have a legal ground in which to do so (i.e., you have given us your Consent and chosen to provide us with this data). We do not collect any Criminal Convictions Data except in the employment context and where we are permitted by law to do so when completing background checks.

How do we collect this? As you interact with our website, we automatically collect this data about you by using cookies and similar technologies (check out our Cookies Notice). We also collect this data through our direct interactions with you and third parties (such as through background check providers).

What’s our legal ground(s) for Processing? One or more of the following apply:

• Consent (i.e., in that you are choosing to provide us with your details so that we can contact you about a vacancy).
• Contract (i.e., in that we need this information to potentially enter into a contract with you).

8. Are you a potential or existing patient?

Thank you for giving us a chance to offer our services to you. We’re really delighted to have the opportunity to help you in trying to grow your family. Our practitioners are experienced, warm and supportive individuals who will guide you as much as possible through our fertility procedures and will comfort you through the experience.

What do we collect? We collect Technical Data and Usage Data (for tracking purposes). We also collect Identity Data, Contact Data, Financial Data, Transaction Data, Profile Data, Special Category Data and Communications & Marketing Data (for when you enter into a contract with us for us to deliver our services).

How do we collect this? As you interact with our website, we automatically collect this data about you by using cookies and similar technologies (check out our Cookies Notice). We also collect this data through our direct interactions with you and third parties (including other health care providers which you have authorised to share your personal data with us).

What’s our legal ground(s) for Processing? One or more of the following apply:

• Contract (i.e., in that we need this information to enter into or perform a contract with you).
• Legitimate Interests (i.e., its necessary for our Legitimate Interests in recovering payments due).
• Legal obligation (i.e., its necessary for us to comply with a legal obligation such as in respect to our financial, tax and legal affairs).

9. Are you a potential or existing third-party supplier?

Thank you for considering working with us or for already providing us with your services. We are grateful for all of the external support that we receive which help us to achieve our mission.

What do we collect? We collect Technical Data and Usage Data (for tracking purposes). We also collect Identity Data, Contact Data, Financial Data, Transaction Data and Profile Data (for when we are engaging you for your services).

How do we collect this? As you interact with our website, we automatically collect this data about you by using cookies and similar technologies (check out our Cookies Notice). We also collect this data through our direct interactions with you (i.e., we will hold Personal Data on your staff that have engaged with us).

What’s our legal ground(s) for Processing? One or more of the following apply:

• Contract (i.e., in that we need this information to enter into or perform a contract with you).
• Legitimate Interests (i.e., its necessary for our Legitimate Interests in keeping records to develop our business strategy).
• Legal obligation (i.e., its necessary for us to comply with a legal obligation such as in respect to our financial, tax and legal affairs).

10. Are you a potential or existing partner?

Thank you for being a part of our journey. We couldn’t do this without you and consider that you play a crucial part in our success in helping our patients.

What do we collect? We collect Technical Data and Usage Data (for tracking purposes). We also collect Identity Data, Contact Data, Financial Data, Transaction Data, Profile Data and Special Category Data (for when we are collaborating with you).

How do we collect this? As you interact with our website, we automatically collect this data about you by using cookies and similar technologies (check out our Cookies Notice). We also collect this data through our direct interactions with you (i.e., we will hold Personal Data on your staff that have engaged with us).

What’s our legal ground(s) for Processing? One or more of the following apply:

• Contract (i.e., in that we need this information to enter into or perform a contract with you such as our terms of collaboration).
• Legitimate Interests (i.e., its necessary for our Legitimate Interests in keeping records to develop our business strategy).
• Legal obligation (i.e., its necessary for us to comply with a legal obligation such as in respect to our financial, tax and legal affairs).

11. Who do we share your personal data with?

We will only share your Personal Data when necessary and have outlined examples of the types of organisations with whom we would share it with:

• Technology companies that provide us with support, hardware and software products (such as Nvoy Technologies and Microsoft) – for us to conduct our business operations.
• Clinical and laboratory consumable providers, sperm donors and medication suppliers (such as the European Sperm Bank and the London Sperm Bank).
• Professional advisers such as law firms, banks, payment providers and accountancy firms (such as Aria Grace Law and Global Payments) – which we need to engage with for the purposes of our business and may need to provide data.
• Regulators and other governmental authorities (e.g., Companies House, HMRC, Home Office and the Human Fertilisation and Embryology Authority) – which we need to engage with for the purposes of our business and may need to provide data.
• Third parties to whom we may be in contact with to sell, transfer or merge parts of our business or assets, or to attempt to acquire or merge with other companies.

We require all third parties to respect the security of your Personal Data and to treat it in accordance with Data Protection Laws. We enter into contractual agreements with all of our third parties (with the exception of regulators and governmental authorities) which include the appropriate data protection clauses.

12. How do we ensure that your personal data is protected?

We have put in place appropriate technical and organisational security measures (such as multi-factor authentication and encryption) to prevent your Personal Data from being accidentally lost, falsified, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your Personal Data to those employees, contractors and other third parties who have a business need to know. We have put in place policies, plans and procedures to deal with any suspected or actual personal data breaches (although we hope not to ever be in that position).

13. How do we protect personal data when it is being transferred across borders?

We ensure that Personal Data is transferred safely and securely at all times. Whenever your Personal Data travels outside of the UK and/or the EEA, we ensure that it’s protected by putting in one of the following safeguards:

• We will only transfer your Personal Data to countries that have been deemed to provide an adequate level of protection for Personal Data as endorsed by the ICO and identified and determined by the European Commission.
• We will only transfer your Personal Data where we have entered into specific contracts with an organisation outside of the UK and/or the EEA which states that they will ensure that your Personal Data has the same level of protection as if it were in the UK and/or the EEA.

If you want to find out the specific mechanism used when transferring your Personal Data out of the UK and/or the EEA, please contact our DPO on privacy@bridgeclinic.london.

14. How long do we keep data for?

We will only keep your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. For example, we would retain fertility records (including all consent forms and any specific instructions relating to the use of embryos) for 30 years from the date of creation in line with the Human Fertilisation and Embryology Act 1990.

To determine the appropriate retention period for Personal Data, we consider the amount, nature and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we Process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

We may retain your Personal Data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you (although, of course, we really don’t want to be in that situation).

As a note, in some circumstances we will anonymise your Personal Data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information without further notice to you.

15. What rights do you have in respect of your personal data?

Under certain circumstances, you have specific rights in respect of the Personal Data that we Process about you. Your rights include:

• Right of access to information and copies of the Personal Data that we hold about you.
• Right to rectify (i.e., correct) your Personal Data where it is inaccurate or incomplete.
• Right to delete your Personal Data, but only in specific circumstances, for example where the Personal Data is no longer necessary in relation to the purpose for which it was originally collected or Processed. It may not therefore always be possible for us to delete all of the information we hold about you if you request this, for example, if we have an ongoing contractual relationship with you.
• Right to restrict Processing in specific circumstances, for example while we are reviewing the accuracy or completeness of data or deciding on whether any request for erasure is valid.
• Right to object to Processing in cases where Processing is based upon our Legitimate Interests or where Processing is for direct marketing purposes (including profiling).
• Right to data portability which means the right to receive, move, copy or transfer your Personal Data to another Data Controller. You have the right to this when we are Processing your Personal Data based on Consent or on a contract and the Processing is carried out by automated means.

If you wish to exercise any of the rights set out above, please contact our DPO on privacy@bridgeclinic.london. You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity. This is a security measure also in your own interest to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within 1 month. Occasionally it could take us longer than 1 month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

We also need to let you know that if you have any concerns and/or you’re not happy with our approach, you have the right to make a complaint to the ICO which can be contacted on www.ico.org.uk. Data Protection Laws are constantly evolving, and we endeavour to maintain best practice. However, we recognise that we may not always get it right and if you are not satisfied in the way we handle your Personal Data, or you wish to discuss our processes then we would really like to hear from you and request that you contact us in the first instance.

16. What other links and features are on our website?

Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements and notices. When you leave our website, we encourage you to read the privacy documentation the website you visit.

17. How do we use your personal data in our marketing practices?

We strive to provide you with choices regarding certain Personal Data uses, particularly around marketing and advertising. We may use your Identity Data, Contact Data, Technical Data, Usage Data and Profile Data to form a view on what we think you may want or need, or what may be of interest to you.

You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing. We will get your express opt-in Consent before we share your Personal Data with any third-party for marketing purposes. You can ask us or third parties to stop sending you marketing messages at any time by contacting us and withdrawing your Consent. Where you opt out of receiving these marketing messages, this will not apply to messages that we need to send you a result of performing a contract that we have with you (e.g., as we may be required to contact you in order to perform the contract).

18. Want to get in touch with us?

We really do believe in the importance of complying with legal and compliance requirements and we hope that we’ve managed to show you this in our approach to data privacy through this Privacy Notice. If you would like more information on our approach to data privacy, please do get in touch with our DPO on privacy@bridgeclinic.london. We’d welcome the opportunity to share more information on our practices with you.