Health Technology Wales (HTW) is strongly committed to protecting personal data. This Privacy Notice explains the following:
- Who are we
- What information do we collect about you?
- How we collect your information, why we need it and how we use it
- Use of automated decision making and profiling
- What legal basis we have for processing your personal data
- When do we share personal data
- Where do we store and process personal data
- How we secure personal data
- How long do we keep personal data for
- Keeping us up to date
- Your legal rights in relation to personal data including your rights to withdraw consent
- How to contact us including how to make a complaint with a supervisory authority
- How and when we review our privacy notice
We recommend you read this privacy notice thoroughly. Please contact us with any questions or concerns regarding our privacy practices. Our contact details are on our website and also contained within this Privacy Notice.
Who are we?
Health Technology Wales (HTW) is a national body working to improve the quality of care in Wales. We collaborate with partners across health, social care and the technology sectors to ensure an all-Wales approach. We are funded by the Welsh Government and hosted within NHS Wales, but are independent of both.
Our remit covers any technology or model of care and support in health and social care that isn’t a medicine. For health, this could include medical devices, diagnostics, procedures and psychological therapies. For social care, this could include equipment, or different models for supporting families, children, adults and the workforce.
We act as a Data Controller and Data Processor in the following circumstances:
- Data Controller – when processing your data to enable us to deliver improvements in the quality of care in Wales
- Data Processor – when required to act as a Data Processor by the Welsh Government
Our privacy notice explains how Health Technology Wales uses personal data. All references to ‘we’ or ‘us’ in this notice refer to Health Technology Wales (HTW)
You can contact us via email on:
What information do we collect about you?
When we talk about personal data or personal information, we are only referring to information from which an individual person can be identified. It does not include data where the identity has been removed.
Our activities across Wales are fundamental to our success. We collect and process information with key stakeholders to help us continue to collaborate with partners across health, social care and the technology sectors to ensure an all-Wales approach. This includes the following categories of information:
- Identity data which includes your name
- Contact data (e mail address, telephone number)
To put this into context, it includes personal data collected as a result of:
- You asking us about our activities
- When you register with us for information
- When you sign up for publications or newsletters
- When you telephone, write, contact us online or text us or otherwise provide us with your personal data
This can include information such as your name, communication preferences, email address, postal address, IP address, telephone number or mobile number.
We do not collect any data defined as special categories of personal data under Data Protection law about you unless there is a clear reason for doing so, for example, relating to your health, and only where appropriate – such as participation in a specific project or programme, or where we need to ensure that we provide appropriate support to enable you to participate in an event or support us in some other way.
We will only collect special categories of personal data with your consent, and clear notices will be provided for events and other relevant forms and communications, so you know what information we need and why we need it.
How we collect your information, why we need it and how we use it
When you contact us regarding the work we do, we will handle your data with the utmost care and are sensitive to the need to handle all data lawfully, fairly and transparently.
You should also be aware of our responsibilities under Freedom of Information legislation, our remit to provide information to meet internal and external audit requirements and our legal obligations (e.g. fraud prevention).
Use of automated decision making and profiling
Health Technology Wales does not undertake automated decision making and profiling
We monitor user activity to enhance content provided on the site. Google Analytics (an external website) is a free service provided by Google (an external website) that generates statistics about the visitors to a website.
Information collected includes referring/exit web pages, click patterns, most/least viewed web pages, session duration, number of visitors, browser type, operating systems etc. Information is collected by using cookies.
A cookie is a small file of letters and numbers which often includes an anonymised, unique identifier. This means that it can be used to identify you without revealing your personal information. When you visit a website, it asks permission to store a cookie in the cookies section of your hard drive. Cookies are widely used on the internet to make websites work, to make them work more efficiently, or to provide information about your usage of the site to the site owner or other third parties. For example, if you add items to a shopping basket, a cookie allows the website to remember what items you are buying, or if you log in to a website, a cookie may recognise you later on so that you do not have to put in your password again.
A third-party cookie is one that is associated with a different domain or website than the one that you visit. For example, on this site, we use third-party cookies built by Google to enable website analytics, but as our site is not on the Google domain, this makes their cookies “third-party” cookies. The Google Analytics cookie will recognise and count the number of people who visit our site, as well as providing other information such as how long visitors stay, where they move to on our site, and what pages receive the most visits. We cannot directly control how Google cookies behave.
How to Disable Cookies
To change your cookie settings:
- Internet Explorer: Please follow this link http://windows.microsoft.com/en-gb/internet-explorer/delete-manage-cookies#ie=ie-9 (external website) for instruction on how to disable cookies.
- Firefox: Please follow this link http://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (external website) for instruction on how to disable cookies
- Chrome: Please follow: link https://support.google.com/chrome/answer/95647?hl=en&ref_topic=14666 (external website) for instruction on how to disable cookies.
What legal basis we have for processing your personal data
We always have a legal basis for processing personal data, the legal basis we use are as follows:
- Where processing is necessary for the performance of a contract to which the data subject is party; or
- Where the data subject has given consent to the processing of his or her personal data for one or more specific purposes; or
- Where processing is necessary for compliance with a legal obligation to which we are subject; or
- Where processing is necessary in order to protect the vital interests of the data subject or of another natural person; or
- Where processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in us (the controller); or
- Where processing is necessary for the purposes of legitimate interests pursued by us or a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require the protection of personal data
To put the use of the six legal Basis’ we use for processing personal data into context we will use the personal data and information we collect for the following purposes:
We must have a lawful reason for processing your personal information. Most commonly, we will use your personal information in the following circumstances:
- send material to stakeholders by post or contacting them by telephone for our legitimate purposes (subject to checking against the Telephone Preference Service and any existing preferences).
- conduct research to better understand who our stakeholders are and better target our activity.
- monitor who we deal with to protect against fraud, money laundering and other risks;
- maintain and administer our stakeholder database and systems.
In all cases, we balance our needs against your rights as an individual and make sure we only use personal data in a way or for a purpose that you would expect in accordance with this Policy and that does not intrude on your privacy or previously expressed preferences.
Where we process special categories of personal data (as mentioned above), we will make sure that we only do so in accordance with one of the additional lawful grounds for processing such as where we have your explicit consent or you have made that information manifestly public.
We will only use your personal information for the purposes for which we collected it, unless we consider that we need to use it for another reason and that reason is compatible with the original purpose. Information is only held for as long as there is a legitimate reason to do so, information that is no longer required is destroyed in such a way that it cannot be reconstructed. If you wish to obtain an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
When do we share personal data?
Disclosure of Information for legal or regulatory purposes
We may need to disclose your information to a third party as part of ongoing programme management and audit requirements.
Additionally, as part of our remit to conduct due diligence we may also need to release information to progress governance checks for specific requirements, programmes, other parties (or projects. We will carry out this process lawfully, proportionately and securely).
Third parties include:
- External advisors and consultants directly engaged with programme/project delivery (please note that all advisors/consultants are bound by confidentiality requirements in their contracts);
- Organisations who are partners with Health Technology Wales.
- Our professional advisers e.g. lawyers, bankers, accountants
- Third party service providers who provide administrative and support services to us
We will ensure that if information is required to be shared, then it will be shared securely, and you will be informed that we have shared it, who we have shared it with and how we shared it.
Where do we store and process personal data?
Personal data is stored within NHS Wales electronic systems. We undertake regular security reviews of all our platforms and conduct risk assessments as required under Article 35 of the EU GDPR and Chapter 2 of the Data Protection Act 2018 (UK GDPR) to comply with our duty as a Data Controller. Please contact our Data Protection Officer for further information should you wish to understand how your data is processed.
How do we secure personal data?
We have in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised manner or otherwise used or disclosed.
To achieve this, we use encrypted secure technology to protect all personal information stored by us. We operate up to date and regularly review policies for Data Protection, Information Governance, Password Policy, Information Security and Business Continuity (including Risk Assessments via the Data Protection Impact Assessment (DPIA) process and individual risk assessments) to support our business processes and to ensure that all personnel are aware of the importance of data security.
Access to information is permitted on a need to know basis.
How long do we keep your personal data for?
We only keep and process personal data for as long as there is a contractual or business requirement to do so or we are otherwise obliged to keep the same under any contractual, regulatory or legal requirement. Once the requirement has expired, the information is deleted safely and securely from our systems in such a way that Information which is deleted is done so in accordance with current security regulations.
Keeping us up to date
As part of our responsibility to ensure that information we hold about you is up to date, we rely on you to keep us updated. We request that where any of your details change, that you inform us so that we may update out records accordingly.
If you tell us that you no longer want to receive further contact from us and you are on our stakeholder database, it may take a short while before our communications stop altogether as it can take up to one month in which to complete your request, although we aim to stop communication as soon as possible. If you request to receive no further contact from us, we will keep the information we hold on you and add you to our suppression lists to ensure that you do not receive unwanted materials in the future.
Your legal rights in relation to personal data including your rights to withdraw consent
As a data subject, you have rights in relation to your Personal data. These are:
- You have a right to access your personal information,
- You have a right for incorrect information held about you to be rectified
- You have a right for information which you no long wish us to hold to be erased (also known as the right to be forgotten)
- You have a right for the processing of your information to be restricted
- You have a right to data portability – for your personal information to be transported in a structured, commonly used, recognisable format
- You have a right to object to the processing of your personal information,
- You have a right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or significantly affects you.
You also have the right to make a Subject Access Request. As part of this process you will be able to ascertain:
- Whether or not your data is processed, and if so why
- The categories of personal data concerned
- The source of the data if you have not provided the original data
- To whom your data may be disclosed, including outside the EEA and the safeguards that apply to such transfers.
We reserve the right to validate your identity prior to release of information.
We will not make any charges for such requests, unless the requests made repeatedly and are considered excessive. We will respond to you request within 1 month of the date of request.
If you have provided consent to Health Technology Wales to process any of your data, then you also have a right to withdraw that consent unless we are contractually or legally obligated to retain data.
In cases where we do not need to retain data for contractual or legal reasons, we will delete the data as soon as possible and at the very least within 1 month from the date of your request.
How to contact us, including how to make a complaint with a supervisory authority
To exercise all relevant rights or should you have any objections or queries relating to how your personal data is being processed by us, please contact our Data Protection Officer at :
Velindre NHS Trust,
For independent advice about data protection, privacy and data-sharing issues, or if you should ever be dissatisfied with the way we have handled your personal data you can contact the Information Commissioners Office (ICO) at:
ICO Wales contact details
Information Commissioner’s Office – Wales
2nd Floor, Churchill House
Telephone: 029 2067 8400
Fax: 029 2067 8399
ICO Head office details
Information Commissioner’s Office – Wycliffe House
Telephone: 0303 123 1113 or 01625 545745
Fax: 01625 524510
Review of the Privacy Notice
We regularly review all of our policies and procedures, we will post updates on our documentation and webpage, this Privacy Notice was last reviewed and amended on the 12th May 2023
Care is taken to ensure that the website content is accurate. Nevertheless, content is provided for general information only, and you use it at your own risk. We will not be held liable for damage or loss ensuing from any act or omission resulting from the use of information on this website.
We reserve the right to make changes to the web site as appropriate from time to time.
We make every effort to check and test material for viruses. However, it is recommended that you run an anti-virus program on all materials downloaded from the internet. We cannot accept responsibility for any loss, disruption or damage to your data or computer system which may occur whilst using material derived from this website.
Health Technology Wales is not responsible for the content or reliability of any linked websites. We accept no liability in respect of the content or for the consequences of following any advice included on such sites.
Listing should not be taken as an endorsement of any kind.
We cannot guarantee that these links will work all of the time and have no control over the availability of the linked pages or change of website address.
Health Technology Wales reserves the right to reject or remove links to any website.