1. Who We Are
We are MB HEALTH CONSULTING LTD, trading as The Gender Hormone Clinic (GHC). Our registered office is at 85 Great Portland Street, London, W1W 7LT (incorporated on 6 August 2024), and we are physically located at Fitzrovia Hospital, 13-14 Fitzroy Square, London, W1T 6AH. You can reach us by phone at +44 7403 925117 or via email at info@thegenderhormoneclinic.com. We are committed to protecting your personal data in accordance with the UK GDPR and the Data Protection Act 2018.
2. Scope of This Policy
This policy explains when and why we collect personal data, how we use it, the conditions under which we may disclose it to others, and how we keep it secure. It applies to all individuals who interact with GHC, whether by visiting our website, completing forms, emailing or calling us, or consulting with us in person.
If our website uses cookies and similar technologies, we obtain consent for any non-essential cookies in line with legal requirements. You can find more details on our cookie practices in Section 13 or a separate Cookie Policy on our website, where applicable.
3. What Personal Data We Collect
We may collect basic personal information such as your name, date of birth, address, phone number, and email address, as well as details for next of kin or emergency contacts. Since we provide healthcare services, we also collect sensitive health-related data, including medical histories, current medications, GP summaries, and consultation notes related to gender transition or hormone therapy. In certain cases, we may process children’s data—such as when minors are referred for services—and will apply additional safeguards, including obtaining the appropriate consent from a parent/guardian or verifying Gillick competence when applicable.
We use Fillout.com to provide online forms. Partially completed forms are retained for a short period (usually 30 days) so that we can remind you to finalise them. If you prefer not to receive such reminders, please contact us at info@thegenderhormoneclinic.com.
4. How We Collect Your Data
You generally provide personal data when you interact with us via online forms, email, phone, or in-person appointments. We may also receive information from third parties, such as your GP or other healthcare providers, if you have given them permission to share your details with us.
5. Why We Use Your Data
We process personal data to provide safe and effective healthcare services, diagnose medical conditions, arrange appointments, communicate with you about your treatment plan, manage billing and other administrative tasks, and comply with legal or regulatory obligations. Sensitive health data is processed either with your explicit consent or as necessary for healthcare and treatment. In certain contexts, such as sending marketing communications (if ever applicable), we rely on your consent. In others, we rely on legitimate interests (e.g., ensuring efficient communication with patients) or on performance of a contract (e.g., billing), legal obligations (e.g., regulatory recordkeeping), or vital interests (e.g., preventing harm).
6. Sharing Your Data
Within GHC, only healthcare and administrative staff with a legitimate need will access your information. Externally, we use reputable third-party providers to store and manage records. These include Splose (patient management software), Fillout.com, Airtable, and Google Workspace. Each provider adheres to data protection law, and you can review their privacy notices on their respective websites. We also work with trusted technology providers to support secure internal processes that operate under strict data protection agreements and robust security standards to safeguard your information.
• Splose: https://www.splose.com/legal/privacy
• Fillout: https://www.fillout.com/privacy
• Airtable: https://www.airtable.com/privacy
• Google Workspace: https://cloud.google.com/terms/cloud-privacy-notice
We do not use automated decision-making or profiling that significantly affects you; all critical decisions related to your healthcare are made by qualified professionals. In rare instances, we may disclose personal data to comply with legal obligations, protect your vital interests (or those of another person), or as required in a legal or regulatory context. You have the right to object to your data being processed by certain administrative technology providers. See Section 9 for details on how to exercise this right.
7. Data Retention
Healthcare records are generally kept for at least eight years from your last contact, in line with NHS guidance and professional standards, unless a longer retention period is required by law. Partially completed forms stored via Fillout.com are retained for up to thirty days. You may request data deletion at any time by contacting info@thegenderhormoneclinic.com. We will honour such requests unless there is a legitimate basis or legal requirement to retain certain records, such as regulatory obligations or defense against legal claims.
8. Data Security
We employ technical and organisational measures to safeguard your personal data. These measures include the use of secure servers, encryption where feasible, strict access controls, and regular staff training on data protection responsibilities. If we become aware of a data breach that risks your rights or freedoms, we will notify you promptly and report the incident to the Information Commissioner’s Office (ICO) as required by law.
9. Your Data Protection Rights
You have the right to:
1. Access: Request a copy of any personal data we hold about you.
2. Rectification: Ask us to correct inaccuracies or incomplete information.
3. Erasure (Right to be Forgotten): Request deletion of your data if it is no longer necessary for the purposes for which it was collected or if you withdraw consent (where consent is the legal basis).
4. Restriction: Limit the processing of your data in specific circumstances (e.g., while we verify accuracy or lawful basis).
5. Objection: Object to processing based on our legitimate interests or for direct marketing purposes.
6. Portability: Receive your data in a structured, commonly used format, or request its transfer to another organisation when processing is based on consent or contract and carried out by automated means.
7. Right to Object to Certain Processing: You have the right to object to the processing of your personal data by specific administrative technology providers where our lawful basis is legitimate interests. If you wish to exercise this right, please contact us at info@thegenderhormoneclinic.com.
To exercise any of these rights, please contact info@thegenderhormoneclinic.com. We may need to verify your identity to ensure we are communicating with the correct individual. We do not charge a fee unless your request is manifestly unfounded or excessive, in which case we may charge a reasonable fee or refuse the request.
10. International Data Transfers
Our third-party providers, including Google Workspace and Airtable, may process data outside the UK or EEA. We rely on Standard Contractual Clauses (SCCs) or other approved mechanisms to ensure a level of data protection equivalent to UK GDPR standards. If you would like more information about these transfer safeguards, please email info@thegenderhormoneclinic.com and we will be happy to provide further details.
11. Updates to This Policy
We may revise this policy to reflect changes in our operations or to comply with new legal requirements. Any updates will be posted on our website with a revised effective date. We encourage you to check this page periodically so that you remain informed of how we protect your data.
12. Contact and Complaints
If you have any questions or concerns about how we handle your personal data, or if you wish to exercise your data protection rights, you can contact The Gender Hormone Clinic at info@thegenderhormoneclinic.com or by calling +44 7403 925117. We have appointed a Data Protection Lead who oversees data protection compliance and can help address more complex concerns. If you remain unsatisfied after contacting us, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO) at www.ico.org.uk.
13. Cookie Usage (If Applicable)
Our website may use cookies or similar technologies to enable essential site features and analyze traffic. Where required by law, we ask for your consent before placing non-essential cookies on your device. You can manage or revoke cookie permissions at any time through your browser settings or a cookie management tool on our website.
If you need further clarification about any aspect of our data processing activities, please contact us at info@thegenderhormoneclinic.com. We take your privacy seriously and are committed to ensuring transparency in how we collect and use personal data.
