Privacy Notice – APL Health
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Privacy Notice

Welcome to APL Health’s privacy policy. In all instances where we mention ‘APL Health’, ‘Smart Clinic’ of ‘Smart Clinic UK’, or ‘us’ ‘we’ and ‘our’, we’re referring to APL Health Limited.

During your interactions with us, we may request information from you to assist with the management and administration of your occupational health and wellbeing package, or the provision of our occupational health and wellbeing services. This includes (but isn’t limited to) personal data, health history information and existing medical conditions.

If you aren’t sure why we’re asking for some information, you have the right to ask us at any time.

This notice sets out who we are, why we collect personal data and how we intend to use this information. We will also tell you who we may share your information with and how you can request access to this information.

This applies to information we collect about:

  • Visitors to our website.
  • People who use our services.
  • People who have entered into a contract with us or have begun the process of entering into a contract with us.
  • Employees of our clients.
  • People identified as having a legitimate interest in our products and services.
  • Our employees/agents and employees/agents of third party companies we engage.
Who are we

We are APL Health Limited, an occupational health and wellbeing provider, and healthcare technology specialist, registered at 9 Brunel Court, Northwich, Cheshire, CW9 7LP. We are responsible for providing advice, therapy, and case/absence management. Any questions relating to data protection or our processing of personal data should be directed to our data protection officer by email to

How we use personal data

We collect personal data to:

  • provide you with any requested quotations.
  • once an agreement has commenced, to manage your package, which may include general administration, sending information, setting up client portal access.
  • implement wellbeing or occupational health provisions that may be appropriate or recommended from time to time.
  • contact you to send marketing, product information or promotional material that we believe you would have a legitimate interest in receiving.
  • Analyse the performance of our products and services to help us develop and improve them.
Why we use personal data

During the course of our dealings with you, we use your information to:

  • comply with our legal and regulatory obligations.
  • develop our products, services and systems to help improve your experience.
  • prevent and detect financial crime and fraud.
  • Provide appropriate information and advice in a manageable format.
  • Request further health and wellbeing provisions.

We may also:

  • share personal data with agents or third parties who carry out certain services or activities as part of your package with us.
  • periodically send promotional materials about new products or other information which we think you may find interesting using the contact information which you have provided.

Further information is provided within our service level agreements.

Types of personal data we collect

We may collect different types of personal data, depending on your relationship with us.

If you have not entered into a contract with us, we may collect:

  • Contact details of those responsible for making the decisions relating to occupational health and wellbeing at your organisation, including names, position and email addresses.

If you have entered into a contract or have begun the process of entering into a contract, we may collect:

  • Contact details of those responsible for making the decisions relating to occupational health and wellbeing, including names, position and email addresses.
  • Details of any persons covered / to be covered under the contract, including names, dates of birth, job details, contact details
  • In the event of a service request being made, this may extend to sensitive personal data such as health/medical information.
Who we share personal data with

Your information may be shared with our agents or appointed representatives who provide specific services or activities as part of the normal operation of your occupational health and wellbeing package such as our physiotherapy provider and our IT Service and Systems provider.

Your information can also be disclosed when we believe that the disclosure is either required by law, to protect the safety of our employees or the public, or in the event of a merger, asset sale or other related transaction.

Sensitive information

When arranging your cover or administering a claim, we may at times ask for sensitive personal data as defined by the General Data Protection Regulations article 9 (medical information for example). We will only use this sensitive personal data for the specific purpose that it is requested for and will only share such information to parties not mentioned within this privacy notice with the data subject’s express consent.

Personal or sensitive information of others

Where you provide us with information about another person (for example an employee), it is your responsibility to ensure that:

  • the individual is aware of who we are and how we may use their information.
  • you have their permission to share that information and have it processed by us.
  • it is recommended that they are provided with a copy of, or instructions to access, this privacy notice so that they will be aware of who we are, how we use personal data and who that data may be shared with.

We have put measures and processes in place to ensure that we process personal and sensitive personal data in accordance with the provisions set out by all relevant data protection laws. It is your responsibility to ensure that you comply with all data protection requirements, whether this is as a Data Controller or a Data Processor.

Sending us information about your health or disability

If you send us any sensitive personal data, including information about your health (such as a medical condition) or your disability, we may use that information to provide the services to our client/s. We will do this in line with any notices provided or consent that we or our client obtains from you and otherwise in compliance with relevant legislation. This includes data protection and equality laws. Where appropriate, it also includes ethical guidelines issued by the General Medical Council, Faculty of Occupational Medicine and others. We may also contact the author of information you send us to confirm it is accurate.

Access to information

Data Subjects have the right to request a copy of all the personal data we hold about them and to know what we use this information for. To request this, you should contact the Data Protection Officer at 9 Brunel Court, Northwich, Cheshire, CW9 7LP. This is referred to as a subject access request and will be processed by us within a month of the request being received. There will be no charge to request this service, however, a small fee may be charged to cover administrative costs in dealing with your request if the request is deemed to be manifestly unfounded or excessive (for example, repetitive requests for information).

Visitors to our website

When you visit our website, we use third party services to collect standard information and details of visitor behaviour patterns to analyse information such as numbers of visitors to specific sections of our website. The information collected in this way is only processed in a way that does not allow you to be identified. We do not make any attempt to identify the individuals visiting our website and will only process personal data in accordance and for the reasons outlined within this privacy notice.

Telephone calls and emails

Please note that telephone calls to or from us may be monitored and recorded for training, monitoring and quality purposes and email communications may be monitored as permitted by UK law.

This privacy notice was last updated in February 2018