Your record, and who is permitted to see it.

01. Who we are

Lucien Health Ltd is the data controller for the information described in this notice. We are a private health management practice registered in England and Wales, and our registered office is 27 Harley Street, London W1G 9QD. We have held member records since the practice was established in 2014.

Controller means that we decide what is held and why, and that we answer for it. Your physician and your care team work within the practice, under our clinical governance and under their own professional registration.

02. The information we hold

We hold what is needed to look after you properly over many years, and nothing collected simply because it was available. In practice that means:

• Identity and contact data: name, date of birth, address, telephone numbers, and the details of anyone you have asked us to speak to on your behalf.
• Clinical records: consultation notes, examination findings, diagnoses, medication and prescribing history, and the report written after each annual assessment.
• Imaging: whole-body and cardiac studies, the images themselves, and the reporting radiologist’s findings.
• Laboratory results, including advanced bloodwork and any repeat panels ordered during the year.
• Genomic data, where sequencing has been carried out with your specific consent.
• Wearable and home-monitoring data, only where you have chosen to connect a device to your record.
• Correspondence with specialists and accredited facilities inside and outside the practice.
• Membership and billing records, including invoices and the costs passed through to you.

03. Lawful basis, and the duty of confidence

Health data and genetic data are special category data under the UK GDPR and carry the highest protection the law affords. We process your ordinary personal data under Article 6(1)(b), because it is necessary to perform the membership agreement between us. We process your health and genetic data under Article 9(2)(h), the provision of health care and treatment by professionals who are subject to a duty of confidentiality.

Where we rely on consent instead, for research, for anything resembling marketing, or for genomic analysis beyond what your care requires, that consent is asked for separately, is specific about what it covers, and may be withdrawn at any time without any effect on your care.

Data protection law is not the whole of it. Every clinician in the practice also owes you the common-law duty of confidence. That duty is older than the statute, it is enforceable in its own right, and it continues to bind our physicians, nurses and phlebotomists after they have stopped working with us.

04. How your record is kept

Your record sits in a single clinical system hosted in the United Kingdom. Data is encrypted in transit and at rest, and backups are encrypted to the same standard and held in the United Kingdom.

Access is granted on a strict need-to-know basis: your named physician, your care team, and the physician covering the member line overnight. Every access to a member record is logged with the identity of the person, the time and the reason. Those logs are retained, reviewed on a schedule, and are auditable. You may ask to see the access log for your own record.

All staff authenticate with multi-factor authentication and on managed devices. Clinical data is never sent as an email attachment. Results, imaging reports and specialist correspondence are released to you through the member portal.

05. Who sees your information

Inside the practice, your care team. Outside the practice, no one, unless you have instructed us in writing. When you ask us to coordinate a specialist opinion, a scan or a procedure, we release the minimum necessary to the named clinician or facility, and we tell you what was sent.

A small number of processors act on our behalf, principally our clinical record provider, our accredited laboratory partners and our imaging providers. Each is bound by a written contract, may act only on our documented instructions, and may not use your data for its own purposes.

Two narrow exceptions sit outside your written instruction: where the law compels disclosure, such as a court order or a statutory notification, and where there is an immediate risk to life. If we ever have to rely on either, we disclose only what is strictly required and we tell you, unless we are prohibited by law from doing so.

06. What we do not do

We do not sell data, and we hold no advertising or data-sharing agreements of any kind. There is no commercial route by which your record leaves this practice.

We do not release your record to insurers, employers, family members, lawyers or financial advisers without your written instruction. Requests from any of them are declined as a matter of course unless that instruction is on file, and we will normally tell you that a request was made.

We do not use member data for marketing. We do not use member data for research, and we contribute to no study, registry or commercial dataset, without separate consent that names the purpose and that you may revoke.

07. Genomic data

Genomic data is treated differently because it behaves differently. It does not change over your lifetime, it identifies you on its own, and it discloses something about your relatives as well as about you.

Sequencing is carried out only with written consent that sets out what will be analysed, what will be reported back to you, and what will be done with incidental findings. Genomic data is stored apart from the rest of your record, under separate access control, and is excluded from routine disclosures to third parties even where you have authorised the release of your wider record.

You may ask us to destroy stored genomic data and any derived sequence at any time. We confirm in writing once it is done.

08. Moving records between our offices

We work from London, Zurich, New York and Singapore. Your record is held in the United Kingdom and stays there by default. It is not moved abroad for storage, cost or administrative convenience.

Where your care requires it, for example an assessment at our Zurich rooms or a specialist opinion in New York, the relevant part of your record is made available to the treating clinician for that episode of care and no longer.

Transfers to Switzerland are made under the adequacy regulations. Transfers to the United States and Singapore are made under the UK addendum to the standard contractual clauses, supported by a transfer risk assessment that we review annually. Copies of the safeguards in place are available on request.

09. How long we keep records

Clinical records are retained in line with professional guidance on medical record keeping. In practice that means at least ten years after your membership ends, and longer where guidance or the law requires it.

Records relating to a child are kept until their twenty-fifth birthday. Records connected to a claim or an investigation are kept until the matter is concluded. Billing records are kept for six years to meet tax obligations. Administrative correspondence with no clinical relevance is deleted after two years.

At the end of a retention period records are securely destroyed, and the destruction is recorded.

10. Your rights

Under the UK GDPR you may:

• Ask for a copy of everything we hold about you, which is known as a subject access request.
• Ask us to correct anything inaccurate or incomplete.
• Ask us to erase data, where no professional or legal obligation requires us to retain it.
• Ask us to restrict processing while an accuracy question or a dispute is resolved.
• Ask for your data in a portable, machine-readable form.
• Object to processing.
• Withdraw any consent you have previously given.

Write to dpo@lucienhealth.com and we will respond within one calendar month. There is no charge. The right to erasure is limited where we are under a professional or legal duty to retain a clinical record, and if that applies we will tell you which duty and for how long.

If you leave the practice, your record is yours to take. That includes imaging in DICOM format, and we will send it to you or to a doctor you nominate.

11. Complaints

If you are unhappy with how we have handled your information, write to our data protection officer at dpo@lucienhealth.com. We acknowledge within five working days and answer in full within twenty.

You also have the right to complain to the Information Commissioner’s Office, the United Kingdom supervisory authority for data protection, at ico.org.uk or on 0303 123 1113. We would prefer the chance to put things right first, but you are not obliged to come to us before you go to the regulator.

12. Cookies, and changes to this notice

This site sets a small number of first-party cookies and no advertising or cross-site trackers. What is set, and why, is listed in our cookie notice.

We review this notice at least once a year, and whenever the way we hold or use information changes materially. Where a change affects you, we write to you before it takes effect rather than relying on you to notice a new date at the top of this page. Earlier versions are available on request.