Clinic & Practitioner Privacy Notice

This Practitioner & Clinic Privacy Notice (the "Notice") is for healthcare practitioners, clinics, and associated administrative staff (collectively "you" or "Practitioners") who register and use the website or mobile application operated by The Health Nav Limited (referred to as "we", "us", "our", or "The Health Nav Limited") to list your services and connect with potential patients ("End-Users").

This Notice explains how we collect, use, disclose, and safeguard the personal data and business information you provide to us when you create a profile, list your services, and use the features available to Practitioners on our website www.thehealthnav.co.uk and our mobile application (The Health Nav) (collectively, our "Services").

This notice includes feature-specific details for our Clinic Directory, including unclaimed/claimable profiles (see Section 6.1).

Please read this Notice carefully. Our general Privacy Policy for End-Users of our platform can be found here - the general privacy policy will apply to any use you make of our services before you sign up as a Practitioner.

We are committed to protecting your privacy and handling your data in an open and transparent manner, in compliance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

For the purpose of the UK GDPR, the data controller for the personal data of Practitioners using our platform is:

The Health Nav Ltd
Albany House, Claremont Lane, Esher, KT10 9FQ
Company registration number: 16453655
We are registered with the Information Commissioners Office with registration number

Email for privacy inquiries: info@thehealthnav.co.uk
Website: www.thehealthnav.co.uk

We have appointed a Data Protection Manager (DPM) who is responsible for overseeing questions in relation to this Privacy Notice. If you have any questions about this Notice, including any requests to exercise your legal rights concerning your data as a Practitioner, please contact our DPM.

DPM Contact Email: info@thehealthnav.co.uk
DPM Contact Address: The Health Nav Limited, Albany House, Claremont Lane, Esher, KT10 9FQ

We may collect, use, store, and transfer different kinds of personal data and business information about you as a Practitioner, which we have grouped together as follows:

Professional Identity Data:

your full name, title, professional registration numbers (e.g., GMC, HCPC), qualifications, certifications, areas of specialisation, years of experience.

Clinic/Business Information:

clinic name, clinic address(es), business telephone numbers, business email addresses, website URL, opening hours, services offered, pricing information you provide for listing, company registration details if applicable.

Contact Data (Personal/Professional):

personal email address and phone number if provided for account management, distinct from publicly listed business contact details.

Account Data:

your username for accessing the Practitioner portal, password (encrypted), your platform preferences, and feedback you provide about our Services.

Financial Data:

bank account details, payment card details for processing payments for our Services to you. If we use Third-Party payment processing services, those Third-Parties will process your bank account and payment card details rather than us – where that is the case, please refer to their privacy policies for details of how they will process your personal data.

Profile Content:

photographs of yourself or your clinic (that you provide), descriptive text about your practice and services, languages spoken, accessibility information.

Technical Data:

internet protocol (IP) address, your login data to the Practitioner portal, browser type and version, time zone setting, operating system and platform.

Usage Data:

information about how you use the Practitioner-specific sections of our website and app (e.g., features used, profile update frequency).

Communications Data:

records of your communications with us (e.g., emails to our Practitioner support team, platform notifications).

Performance Data:

Anonymised or aggregated data related to your listing's performance on our platform, such as number of views or End-User interactions (e.g., clicks to your website, booking requests if facilitated by us).

Clinic directory data (including unclaimed/claimable profiles):

clinic name, address, public contact details, services, opening hours, practitioner names/registrations where publicly available. See Unclaimed/Claimable Clinic Profiles (UK) for details.

We collect data from and about you primarily through:

Direct interactions:

You provide us with most of your Professional Identity, Clinic/Business, Contact, Account, Financial (if applicable), and Profile Content data when you:

• Register for a Practitioner account on our platform.
• Create and update your public profile.
• Subscribe to our services (if applicable).
• Communicate with us.

Automated technologies or interactions:

As you interact with the Practitioner portal of our Services, we may automatically collect Technical Data and Usage Data. We collect this data by using cookies and other similar technologies. Please see our general Cookie Policy for further details (ensure it covers Practitioner portal usage).

Public sources and data partners:

We create some Clinic Profiles from public sources (e.g., regulator/professional registers, clinic websites, business listings) and licensed data partners. For sources, verification and how clinics can claim profiles, see Section 6.1.

We will only use your data when the law allows us to. The table below describes the ways we plan to use your data and the legal bases we rely on.

Legitimate Interests: Where we rely on legitimate interests, we ensure we balance our interests against your rights and freedoms. You can obtain more information about our legitimate interest assessments by contacting us.

Consent: Where we rely on consent (e.g., for non-essential marketing), you have the right to withdraw your consent at any time by contacting us on the contact details set out in paragraph 15 below.

We may share your Practitioner data as follows:

Publicly on Our Platform:

The core purpose of your registering is to make your Professional Identity, Clinic/Business Information, and Profile Content visible to End-Users of our platform. You control what information is displayed in your public profile through your account settings.

Service Providers (Data Processors):

We engage third-party service providers for functions such as cloud hosting, payment processing (if applicable), platform analytics, email delivery for service communications. These providers are contractually bound to protect your data and use it only on our instructions.

Professional Advisers:

Including lawyers, bankers, auditors, and insurers who provide services to us, where necessary.

Legal or Regulatory Obligations:

If required by law, or by regulators, courts, or other public authorities.

Business Transfers:

In connection with any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company. We do not otherwise sell your Practitioner personal data.

With End-Users:

If you use platform tools to communicate or confirm bookings with them directly through our Service. The information shared would be that which is necessary for such interaction, as facilitated by the platform at your initiation.

For feature-specific processing (e.g., reviews, clinic directory and claiming), see the dedicated subsections below.

PECR for outreach: We may send B2B claim invitations to corporate subscribers with an opt-out; for sole traders/partnerships we only email/SMS with consent where PECR requires it (you can still call unless TPS/CTPS-listed).

We may transfer your personal data to service providers that carry out certain functions on our behalf. This may involve transferring personal data outside the UK to countries which have laws that do not provide the same level of data protection as the UK law.

Whenever we transfer your personal data out of the UK to service providers, we ensure a similar degree of protection is afforded to it by ensuring that the following safeguards are in place:

• We will only transfer your personal data to countries that have been deemed by the UK to provide an adequate level of protection for personal data, for example countries in the EU.
• We may use specific standard contractual terms approved for use in the UK which give the transferred personal data the same protection as it has in the UK, namely the International Data Transfer Agreement or The International Data Transfer Addendum to the European Commission's standard contractual clauses for international data transfers. To obtain details of these contractual safeguards, please contact us using the details in paragraph 15.

Where Clinic Profile data involves personal data transferred outside the UK (e.g., to hosting, verification, or anti-fraud providers), we use appropriate safeguards such as the International Data Transfer Agreement (IDTA) or the UK Addendum to the EU Standard Contractual Clauses. See Section 6.1 for the vendors involved in Clinic Profiles.

We have implemented appropriate technical and organisational security measures to protect the personal and business data you provide as a Practitioner from unauthorised access, use, alteration, or disclosure. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

Clinics

• Verification artefacts for claimed profiles are access-restricted, minimised, and retained for a short period strictly for fraud-prevention and audit.
• Edit/claim actions are logged to prevent impersonation and misuse.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

We will only retain 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. 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.

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.
• The applicable legal, regulatory, tax, accounting, or other requirements.

If you would like to discuss our retention periods, please contact us using the details in paragraph 15.

Upon expiry of the applicable retention period, your data will be securely deleted or anonymised.

Under UK data protection law, you have a number of rights in relation to your personal data. These include the right to:

• Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully, or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
  • If you want us to establish the data's accuracy.
  • Where our use of the data is unlawful but you do not want us to erase it.
  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise, or defend legal claims.
  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party (data portability). We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data (as explained in Section 7 and 8). However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Clinic Profiles (unclaimed or claimed):

• Directory data retained while needed to provide the service and for accuracy (unclaimed inactive clinics: 30 day grace period)
• Verification artefacts (claim evidence, codes, logs): retained for 90 days after verification or dispute resolution, then deleted or irreversibly anonymised;
• Audit/security logs related to claims/edits: retained for 72 months / 6 years.

Exercising your rights:

To exercise any of these rights, please contact us or our DPM using the contact details provided in this policy (Section 3 or 4).

• You will not usually 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 may refuse to comply with your request in these circumstances.
• We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure 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 one month. Occasionally it may take us longer than a 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.

If your details appear on a Clinic Profile (e.g., you are a sole trader or named practitioner), you can object, request correction, or request redaction of personal contact details where appropriate. See Unclaimed/Claimable Clinic Profiles (UK) for how to verify your relationship to a clinic and submit a request.

The Practitioner portal of our Services may use cookies. Please refer to our Cookie Policy for details on how we use cookies and how you can manage them.

Who provides this service.

We use Zoho CRM, provided by Zoho Corporation (Zoho Corporation B.V., Netherlands; Zoho Corporation Pvt. Ltd., India; and Zoho Corporation, USA), to manage our customer, practitioner, and clinic relationships and to help us meet our legal obligations around consent and privacy requests.

Our role and Zoho's role.

We are the data controller for personal data we store in Zoho. Zoho acts as our data processor and processes personal data on our instructions under a data processing agreement (including the EU/UK Standard Contractual Clauses for international transfers).

What we send to Zoho.

Depending on your relationship with us (e.g., user/patient, practitioner, clinic manager), we may store the following data in Zoho:

• Contact & account data: name, email address, phone number, professional title, website URL, and descriptive tags related to services or specialties; limited clinic details (e.g., clinic name, address, phone, website, listing status).
• Practitioner verification & registrations: verification status (e.g., pending, verified, denied, needs revision), registration body and number, expiry dates, and related operational notes (we store supporting documents in our secure storage, not in Zoho).
• Consent records: consent type (functional, analytics, marketing, health-data), the action taken (given/revoked), capture method (e.g., web app), timestamp, and where available the source IP and user agent string.
• Data subject rights (DSR) logs: request type, status, date received, identity verification status, and operational notes necessary to track and fulfil privacy requests.
• Internal identifiers: our system IDs (e.g., user ID, practitioner ID, clinic ID) for reconciliation and audit.

What we receive from Zoho.

We also receive status updates from Zoho (via secure webhooks) such as practitioner verification outcomes, clinic issue reports (e.g., takedown/unpublish requests), and submitted consent/DSR forms that you or your clinic may complete through our Zoho-powered workflows.

Why we process this data (legal bases).

• Contractual necessity: to provide and manage your account, practitioner listing, or clinic services.
• Legitimate interests: to operate a CRM, keep accurate records, provide support, prevent abuse/fraud, and improve our services while protecting your rights and freedoms.
• Consent: to record and honour your marketing and cookie/analytics preferences, and where applicable your explicit consent for processing special-category health data.
• Legal obligation: to demonstrate compliance with privacy and marketing laws and to respond to data subject requests.

International data transfers.

Zoho may process data outside the UK/EEA. Where this occurs, we rely on appropriate safeguards, including the EU/UK Standard Contractual Clauses and Zoho's published security and privacy commitments. You can contact us for details of the applicable safeguards.

Retention.

• CRM/contact & account data: retained while you have an active relationship with us and for up to 6 years thereafter for record-keeping and legal purposes.
• Consent logs: retained for the duration necessary to demonstrate compliance (typically at least 2 years, and up to 6 years for audit/legal purposes).
• DSR logs: retained for up to 6 years to evidence compliance with privacy requests.

We may retain data longer where required by law, to resolve disputes, or to enforce agreements.

Security.

We configure Zoho with access controls and audit logs. Zoho implements technical and organizational measures appropriate to the risk, and we ensure any sub-processors engaged by Zoho are subject to equivalent protections.

Your choices and rights.

You can update your consent preferences at any time in the app (e.g., marketing emails, analytics/cookies). You also have the right to access, rectify, erase, or restrict processing of your personal data, to object to processing based on legitimate interests, and to data portability. Where processing is based on consent, you may withdraw your consent at any time; this does not affect the lawfulness of processing before withdrawal.

We keep our Privacy Policy under regular review and may update it from time to time. Any changes we make to our Privacy Policy in the future will be posted on this page and, where appropriate and significant, notified to you by email, an in-app notification, or a prominent notice on our website. The "Effective Date" at the top of this policy will indicate when it was last revised. We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your information.

We aim to resolve any queries or concerns you raise about our use of your information directly. If you have any concerns about our use of your personal data, please contact us or our DPM first (see Section 3 or 15 below).

You also have the right to lodge a complaint at any time with the Information Commissioner's Office (ICO), the UK's supervisory authority for data protection issues.

The ICO's contact details are:
Information Commissioner's Office
Wycliffe House, Water Lane
Wilmslow, Cheshire, SK9 5AF
Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk

We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.

For any questions about this Practitioner & Clinic Privacy Notice or our data protection practices concerning your Practitioner data, please contact our Data Protection Manager:

Email: info@thehealthnav.co.uk
Postal Address: Albany House, Claremont Lane, Esher, KT10 9FQ