Privacy Policy — Work Doctor OH Medicals Ltd

1. Who We Are

Work Doctor OH Medicals Ltd (“Work Doctor OH”, “we”, “us”) provides professional occupational health (OH) services to employers and their employees. This policy explains how we collect, use, share, and protect personal data — including health data — across our website, booking system, and clinical services.

Company number: 15535860

Registered office: 1a Davenport Road, Coventry CV5 6QA

ICO registration number: ZB768928

Data Protection Officer: Dr Sarwar Chowdhury — [email protected]

2. The Data We Collect

We collect and process two distinct categories of data, kept in separate systems:

• Personal identifiers (e.g. name, date of birth, phone number, email, employer/company name) — collected via our website and our booking system (Amelia), for scheduling and administration purposes only.
• Special category health data (e.g. medical history, clinical findings, fitness assessments) — collected during occupational health assessments and stored only in our secure clinical IT system.

We do not store special category health data within the website booking system.

3. Lawful Basis for Processing

We rely on the following legal grounds under UK GDPR:

• Article 6(1)(f) — legitimate interests: processing referral and assessment data to deliver occupational health services under our contract with the referring employer.
• Article 9(2)(h) — health or social care assessment: processing special category health data as part of an occupational health assessment carried out by, or under the responsibility of, a health professional subject to a duty of confidentiality.
• Where relevant, your consent to attend and participate in an assessment is also obtained, in addition to (not instead of) the above.

4. How We Handle Occupational Health Reports and Disclosure to Employers

This section reflects our core confidentiality commitment, introduced following a review of our disclosure procedures.

• Clinical information gathered during an occupational health assessment belongs to you. It is confidential to Work Doctor OH and is not the property of your employer, manager, or HR department.
• Except in an emergency (see below), you will always be shown the occupational health outcome before it is shared with your employer, and given a reasonable period — normally 24–48 hours — to review it and raise any factual query.
• Only the agreed outcome is shared with your employer: the overall fitness outcome (e.g. fit / fit with adjustments / unfit), recommended adjustments or restrictions and their duration, and any recall or review date.
• Diagnoses, symptoms, test results, clinical narrative, or anything you tell us during your consultation beyond the agreed outcome will never be disclosed to your employer without your explicit, specific consent.
• Where your employer has its own separate, verified occupational health provider (distinct from your manager), your report may instead be sent to that provider, who is independently responsible for showing it to you before any onward disclosure. A manager’s own personal clinical or occupational health qualifications do not make them a separate occupational health provider, and a report will never be released to a manager on that basis.
• Emergency exception: in a genuine emergency — for example, an immediate and serious risk to your safety or the safety of others — we may share urgent, relevant information with your employer or another appropriate party without prior sight by you. This exception is applied narrowly and only where delay would itself cause harm.

This practice is underpinned by the common law duty of confidentiality, Faculty of Occupational Medicine (FOM) ethics guidance, and applicable professional standards (GMC/NMC) governing our clinical staff.

5. Data Sharing

We share data only as follows:

• With your employer: limited outcome-level information only, and only after the process described in Section 4 has been completed.
• With a verified separate occupational health provider, where one exists for your referral (see Section 4).
• With Amelia, our website booking plugin, which holds personal identifiers (name, contact details, appointment details) only — it does not receive or store clinical/health data.
• We do not sell or share your data with third-party marketers, and we do not share your data with any other third party beyond those listed above.

6. Data Storage and Security

All data is stored within the United Kingdom.

• Personal identifiers collected via our website are held within our booking system (Amelia).
• Special category health data is stored separately, within our secure clinical IT system (Microsoft OneDrive for Business), with access restricted to authorised clinical and administrative staff on a need-to-know basis.

7. Data Retention

We retain data only for as long as necessary for the purposes for which it was collected, in line with the UK GDPR storage limitation principle:

• Website/administrative data (personal identifiers only): retained for 120 days following completion of service, after which it is deleted unless a longer period is required for a specific administrative purpose.
• Clinical health records: retained for 7 years from the date of the last entry, consistent with general Faculty of Occupational Medicine (FOM) guidance and accepted occupational health sector practice, which typically recommends retention in the region of 7–10 years in the absence of a single mandated standard.
• Statutory health surveillance records (e.g. HSE-regulated exposures): retained for up to 40 years, in line with Health and Safety Executive (HSE) requirements for statutory occupational health surveillance records.

Where a record is required for an ongoing legal or regulatory matter, it will be retained for as long as that matter requires, regardless of the periods above.

8. Cookies

We use cookies to support website functionality and analytics, including short-term cookies to check browser cookie acceptance, and login cookies to save display preferences. A full list of cookies used on this site is available via our cookie policy tool (at the bottom of this page).

9. Your Rights

Under UK GDPR, you have the right to:

• Request access to the personal data we hold about you.
• Request correction of inaccurate or incomplete data.
• Request erasure of your data, subject to the exception below.
• Request restriction of, or object to, certain processing.
• Request that we transfer your data to another organisation, where technically feasible.

Clinical record-keeping exception: because we are subject to professional and regulatory obligations to retain clinical records for defined periods (see Section 7), we cannot erase clinical records before the applicable retention period has ended, even if you request this. Where this applies, we will explain the specific obligation that prevents erasure.

To exercise any of these rights, contact our Data Protection Officer, Dr Sarwar Chowdhury, at [email protected].

10. Complaints

If you are unhappy with how we have handled your data, please contact our Data Protection Officer in the first instance at [email protected]. You also have the right to lodge a complaint with the Information Commissioner’s Office (ICO) at ico.org.uk, or by calling 0303 123 1113, if you believe your data has been mishandled.

11. Bookings and Cancellations

• Bookings are managed via our WordPress-integrated Amelia system. By booking, you agree to provide accurate personal identifiers.
• We require notice for cancellations or rescheduling — see your booking confirmation email for specific timeframes. Failure to provide adequate notice may result in a cancellation fee or forfeiture of the appointment cost.
• Remote assessments include a full report and action plan. For face-to-face assessments, please contact us directly to discuss costs, including travel.

12. Intellectual Property and Content Protection

All content on this website — including text, logos, clinical descriptions, and images — is the exclusive property of Work Doctor OH. Users and third parties are strictly prohibited from copying, reproducing, or using any website content or images on any other third-party website or platform without express written consent from Work Doctor OH.

13. Changes to This Policy

We may update this policy from time to time. Material changes will be dated and, where appropriate, notified to service users. The “Last Updated” date at the top of this page reflects the most recent revision.