Embody is a company registered in England and Wales under company number 08139224, having our registered office at 59b Thornhill Road, London N1 1JT and our main trading address at Embody Orthopaedic Limited, 7L24, Lab Block, Charing Cross Hospital, London, W6 8RF.
The primary purpose of the Site is to provide a resource to enable surgeons to:
set up a clinical profile for a patient requiring surgery;
record information relating to a patient as part of their case, including the information referred to at section 2 below ("Case Details");
design and produce (using our surgical planning services) a surgical plan for a particular surgical procedure or set of procedures for a Patient ("Surgical Plan");
design and produce (using our 3D printing services) a 3D model of a surgical guide or bone model to aid a particular surgical procedure or set of procedures for a patient ("Guide"); and
to share Case Details with selected health care professionals (including other surgeons, members of their clinical teams and associated administrative staff) and/or academic researchers in accordance with this Data Handling Policy.
Embody is registered with the UK Information Commissioner's Office as a data controller under registration reference: ZA148948.
For patients we process the following information provided, which are necessary to enable us to supply the Surgical Plan and Guide, and to ensure patient safety:
date of birth;
CT-data, where uploaded;
X-rays, where uploaded;
Patient ID from scanning centre/hospital;
information as to surgery type;
other personal and physical or mental health details relevant to an individual case;
date of surgery;
identity of operating surgeon;
side to be operated on;
implant to be used;
location of the operation;
family details (not normally required – but may be entered by the surgeon into the notes or comments section of a given case where relevant, eg: “family history of orthopaedic problem”);
details of the goods and services required so we can deliver the correct product or service; and
case notes (where provided by or on behalf of a surgeon).
Occasionally we may request more information to aid the creation of a Surgical Plan, which may be in the form of clinical notes and/or media (X-rays, MRI etc).
We also collect and process information about other professional users of the site (such as surgeons, other members of the care team and administrators), including:
details of hospital or other medical centre at which that user is based;
surgical preferences, to aid generation of initial surgical plan;
reasons for working with/becoming a registered user of the Site; and
education details, which may be requested as a validation step upon initial sign-up.
This is done principally for the purpose of verifying the identity of individuals, and to allow the proper performance by Embody as operator of the Site and provider of the Surgical Plan and/or Guide.
Embody will also process and store certain anonymised or aggregated data which does not allow a particular individual to be identified, for example anonymised scan data, non-personal information relating to usage of the site, aggregate data and usage statistics.
If you are a patient and are aware that Embody's services are being used and feel that you have not been properly informed and/or consented to this, please contact us on firstname.lastname@example.org
HOW WE USE PERSONAL INFORMATION
Embody's staff will use the Case Details submitted for the purpose of creating Surgical Plan and Guide and for ensuring patient safety. For example:
our surgical planners use:
the scan data (and other relevant Case Details) to create the (3D) Surgical Plan; and
the name and dates of birth of patients to verify they are the correct patient, when creating a Surgical Plan; and
(in situations where a patient name is not provided) a unique patient identifier to verify they are the correct patient, when creating a Surgical Plan.
our staff involved in the manufacture and assembly of the Guide use:
the scan data (and other relevant Case Details) to manufacture and assemble the Guide; and
the patient names to validate the correct Guides are being produced; and
(in situations where a patient name is not provided) a unique patient identifier to validate the correct Guides are being produced.
We follow the "minimum required" rule when processing data, ie we all to staff access only to data that is necessary to enable them to fulfil their duties, on any given case.
We also use certain Case Details for training of Embody staff and for research purposes, but only in anonymised form.
We never use patients' or other users' personal information for marketing purposes, except where we have the individual's explicit consent to do so or where we use it in anonymised form.
SHARING PERSONAL INFORMATION
We will not share any personal information with any third party other than:
(via the Site) to those members of the care team who the surgeon allows access to a case when the case is uploaded; or
as may be required by a court or other regulatory body who has sufficient legal authority to require such disclosure; or
where we have consent from the individual to whom the information relates; or
when we believe that disclosure is necessary to protect our rights, combat illegality and/or or respond any legal process served on Embody.
Embody may also need to transfer personal information upon a sale or other transfer of all or a substantial part of all of its business, but any such transfer would be subject to Embody receiving suitable undertakings around confidentiality and protection of personal information being obtained from any potential buyer/transferee.
LOCATION, STORAGE AND SECURITY
Embody understands the importance of keeping personalinformation safe and secure. Embody uses its commercially reasonable efforts to protect personal information and ensure the security of our premises and systems.
Any patient identifiable information (such as patients' names and dates of birth) held in electronic form is stored on servers in the UK and encrypted both in transit and at rest using industry standard encryption processes.
Any information held in physical form is securely stored in our UK offices.
We will generally remove scan data from the Site on cases that have been completed (and simply retain a reference to the scan data).
We keep other data (non-anonymised) for a minimum of 5 years as required by our traceability processes in our ISO quality management system. The surgeon and other members of the care team (the users on that case) will still have access to such Case Details during this period, and will be able to view their Surgical Plan in 3D online.
The Act gives data subjects the right to access information held about them. Patient's right of access can be exercised in accordance with the Act. Any access request may be subject to a fee of £10 to meet our costs in providing the patient with the information we hold on him/her. Please refer any request via email to email@example.com
Any changes we may make to this Data Handling Policy in the future will be posted on the Site or otherwise notified in writing.
Questions, comments and requests regarding this Data Handling Policy are welcomed and should be addressed to firstname.lastname@example.org