Automated Decision Making is where a decision is made by a computer algorithm without a human intervention.

HN-Company uses data science to analyse de-identified historical health data across multiple data sources to identify the factors that influence positive or negative health outcomes for patients in a particular population. We have found the factors that influence outcomes vary from population to population, for example if the population is mainly urban or mainly rural the factors may be different.

Our analysis outputs a set of impactful characteristics which have a range of influences, strong to weak. Collectively, these characteristics, weighted to balance the strong and weak influences, are used to create an algorithm we apply to current de-identified health data to identify the people for who an intervention by our health coaches will most positively change their health outcomes. This cohort of people are then re-identified and may be contacted and offered some sort of intervention. If this intervention is commissioned from HN, it will be our coaching service.

In the course of delivering our services, we typically continue to monitor outcome data to further refine our algorithm. It is possible that people will be excluded by the algorithm from being offered additional services, therefore these people will see no change in their standard of care. 

The people identified as those who would potentially benefit from our coaching service are then further screened by our healthcare professionals before they are invited to participate. This further manual screening by healthcare professionals means that our process is not automated decision making.

Website users 

See our Cookie Policy on our website for details about personal data we process on website visitors and how you can control this. 

Customers 

We process information about existing, past and potential customers for sales, marketing, accounting and operational purposes, and where required by law.

Suppliers 

We process information about existing, past and potential suppliers for purchasing, accounting and operational purposes, and where required by law.

Investors

We process information about existing, past and potential investors for marketing and compliance purposes, and where required by law.

Statutory reporting

HN-Company are subject to the laws on the UK and may be required to report personal data to government bodies, for example: HM tax and revenue, immigration, DVLA, etc.

Police or Courts

Very rarely we may be asked to share data we process with the police or courts. Releasing data typically requires a court order or request from someone in the rank of Commander or above.

Employees

We process personal data about people that work for us, have worked for us, apply to work for us, have applied to work for us, or might want to work for us in the future. This data is processed for payroll, pension, tax, employer statutory duties, monitoring, training, performance management, reference taking, management, discipline and any other management of people duties of an employer.

Your right of access to data processed about you 

Where we process data about you from which you can be identified, you have a right of access to that data under most circumstances if HN-Company is the controller (accountable). There are a few exemptions, and we will tell you if these apply to your request.

See below for how to request access to the data we process about you.

Your right to rectify inaccuracies

Where you have reason to believe the information we process about you, for which we are the controller, is wrong, you have the right to request it is corrected and, if we can’t do this, for us to explain why.

See below for how to request an amendment to the data we process about you.

Your right to erasure

Where we process data about you from which you can be identified, you have a right to request that the data be erased under limited circumstances if HN-Company is the controller (accountable). If we can’t do this, for us to explain why.

See below for how to request erasure of the data we process about you.

Your right to restrict processing

In circumstances where we cannot erase or rectify your data, for example where we have a legal duty to retain your data, you can request that we limit unnecessary processing.

See below for how to request erasure of the data we process about you.

Your right to data portability

Where you have requested a copy of the data we process about you, you have the right to receive that data in a structured, commonly used and machine-readable format and be able to transmit those data to another controller without hindrance where possible.

Your right to object

You have the right to object to the processing of your personal data. In the first instance, you should contact us (see How to Contact Us above) and, if you are not satisfied by our response, to make a complaint to the regulator (see Complaints below). 

How to exercise your rights

Contact us using one of the methods below and providing your NHS number (if applicable), name, Post Code, and tell us about what you would like us to do.

Contact Methods

Email:            [email protected] 

Phone:              020 8064 3221

What Happens Next

1. We are required by law to take further steps to validate your identity.
2. We will tell the controller not to send us any further information relating to you (if applicable). It may take a time for this information to fully pass through all systems.
3. Coaching will not be offered to you. Your regular care will not be affected in any way

If you are a service user, customer, supplier or have another relationship with HN-Company, and are based outside the UK in a country covered by the EU General Data Protection Regulation (EU GDPR), then we may transfer your data to the UK.

The UK has been designated ‘adequate’ by the European Data Protection Board as it offers sufficient legally enforceable controls to offer equal protection to citizens as EU GDPR, and therefore no additional measures are required for transfers UK > EU or EU > UK.

In the event that HN-Company uses data processing services in countries outside of EU member states, and these are not designated as having adequate legal protections for personal data, the appropriate and approved additional measures will be implemented. There are no such personal data transfers at this time.

If you would like more information about how HN-Company processes and protects your data, please contact our Data Protection Officer at: [email protected]

If you wish to make a complaint about Health Navigator’s processing of your data, please write to: Information Commissioner’s Office, Wycliffe House, Water Lane, Cheshire SK9 5AF, United Kingdom; or visit: www.ico.org.uk/make-a-complaint for more contact options.

HN-Company has a strong focus on ethical processing of personal data, and all operations are consistent with the NHS Caldicott Principles [see here], data protection laws and norms of the countries in which we operate.

In the UK, HN is compliant with the Data Protection Act 2018 and UK General Data Protection Regulation (GDPR), as well as respecting the Common Law Duty of Confidentiality and NHS specific practices, including the NHS Care Records Guarantee, NHS Constitution, Caldicott Guardianship, and annual completion of the NHS Data Protection and Security Toolkit assessment.

Outside the UK, we apply the same principles, and comply with local laws, particularly those that relate specifically to health data in addition to country-specific data protection laws implementing the EU general Data Protection Regulation.

We try to be as transparent as we can in each project, working with local patient groups to develop communication materials that explain what we do as accessibly as possible.

This co-produced communication material takes many forms, is often produced in multiple languages and is made available and delivered through a variety of communication channels to facilitate all levels of access need.

Our communication materials and channels are continuously reviewed to ensure we keep up with the latest technologies and trends.

We emphasise the need for, and importance of, building algorithms that are effective and safe, as well as protecting patients’ confidentiality.

We train our models using anonymised or strongly pseudonymised data, using the minimum possible data to support our data scientists. For example, we use age and age range groups rather than date of birth, and Lower Super Output Area (comprising 400 and 1,200 households and usually a population of 1,000 and 3,000 people) rather than full postcode.

HN processes a core set of data fields that have proven to have the most predictive impact. The predictive model is built on these data uniquely for each population and as a part of the fine-tuning and model optimisation processes, some of the data fields may be population specific. We seek to minimises the use of identifiable patient data at every step of our operations.

Safeguarding patients’ rights and privacy means that data must be used transparently with a clear description of the purpose, methods and timing. Patients who have agreed to engage with our coaching service are provided with a Privacy Notice that explains what data is processed, the purposes for that processing and the lawful basis for doing so. They are asked for their consent to process additional data captured for secondary uses, for example surveys to help measure patient benefits in the form of evaluations of Patient Reported Outcome Measures (PROMS). Patients are given a clear choice to opt-out from any further collection and sharing of their personal data.

If a patient chooses not to engage with the coaching service when offered, we will delete their identifiable data but retain a ‘stub’ record so that we do not contact them again.

Our clinical coaches are registered healthcare professionals, who have extensive training and experience in accessing and protecting patient information in their daily duties. All HN staff who have access to patient records adhere to strict data protection policies and attend annual Data Protection training revalidation. Our clinical coaches and analysts only have access to patient information via secure servers. In the UK, HN is compliant with the NHS Data Security and Protection Toolkit (DSPT) and has achieved a minimum “Standards Met” each year.

HN uses advanced security measures to protect data. All information is stored in highly secure data centres with special healthcare network connections. Your data is always encrypted, which means it's scrambled so only authorised people can read it.

Only healthcare professionals can view patient records. On HN’s system, our technical team may sometimes need to see identifiable data to keep things running safely and smoothly. Everyone at HN has passed a DBS check and completed training on confidentiality and GDPR.

Logging in requires two-factor authentication (an extra security step), and we carefully track who accesses records and what they do.

We may also use pseudonymised data (where personal details are hidden) to help improve our service.

If you've opted out of NHS data sharing, your data will not be included in our system. You will need to opt back in if you want your information to be used.

Only healthcare professionals can access healthcare records. The technical team can access the data for safety, maintenance and quality purposes. Everyone at HN have been DBS checked. Accessing our systems requires two-factor authentication (an extra security step) to log in and we have various methods of auditing who has accessed records and what activity they have undertaken. 

When appropriate to the stage of processing activity, any information that could uniquely identify you is removed or obscured and any sensitive data if filtered out as defined by NHS England. This might mean that the remaining data is anonymous or pseudonymous. 

De-identified data has all personal details removed. Pseudonymised data includes some ‘keys’ that can be used to re-identify you if combined with other information. Whereas anonymous data does not include these ‘keys’ and is very hard to re-identify an individual without unexpected effort. Also, it is illegal in the UK to attempt to re-identify de-identified data.

HN pseudonymous data includes a practice identifier, an anonymised but consistent patient identifier, an internal reference number, your NHS number, and your date of birth. These are all protected and coded.

Yes, you can opt out at any time.

We use a special process (salted on-way hash) approved by the health service to convert your NHS number and date of birth into a code that can't be easily reversed. Although we can’t reverse this process, because it is always the same, we can still link data over time and from different sources.

We follow strict NHS guidelines and use multiple layers of security. Your data is only used if you haven't opted out, it's stored securely, and access is strictly controlled. Security measures are monitored and tested. You're always in control of your data sharing preferences.

The NHS ensures your information stays safe. The Clinical Coaching Program cannot look at any personal details like your name and birthday when finding patients who might need extra care. They only use data like age and health issues in a way that protects your identity. 

Only when the Clinical Coaching Program thinks extra care might help, can the NHS share your name and contact details with the coaching team to reach out to you. Only people helping with care will be able to see this information. This helps us offer care while keeping your information private.

Your personal information is safe partly because of legal duties in privacy laws like GDPR, Data Protection Act 2018 and the Computer Misuse Act 2022, but also because the NHS and its partners take special care to keep your information secure and private, so it won’t be misused or lost. 

We respect your right to choose whether to participate in our Clinical Coaching Program. If you wish to not participate, please see How to exercise your rights in our Privacy Notice