Isla patient privacy notice
Purpose
This notice is for patient data subjects. If you are a user data subject, you can review our user privacy notice here.
This page will inform you about how we at Isla look after your data and tell you about your privacy rights and how the law protects you. (References to “us”/”we”/”our” in this Privacy Notice means Isla (registered: ISLACARE LTD.) which is registered in England and Wales under company number 12108076.
You must read this privacy notice together with any other privacy notice, or fair processing notice we may provide on specific occasions. This ensures that you are fully aware of how and why we are collecting or processing personal data about you.
Key information:
Who we are
Isla is a remote healthcare technology company providing a patient monitoring platform. The Isla platform allows those involved in your care to request and capture important data to help them assess and manage your health conditions. Isla is web-based and supports the secure capture of data with encrypted storage in the cloud. The data can be accessed only by the team that has captured the data, vetted Isla staff, and any specialists that they wish to pass the data on to.
Where clinically necessary for your continuing care, this may include sharing your data with General Practitioners or clinical staff at other healthcare organisations involved in your treatment, at the instruction of your registered healthcare provider.
Data Protection Officer
We have appointed a Data Protection Officer (DPO) who is responsible for overseeing questions concerning this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.
Isla’s DPO: Mark Bartlett | Email: dpo@isla.health
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
The data we collect about you and how we collect it
We may collect, process, store, and transfer different kinds of personal data which we have grouped as follows:
Personal demographic data
This data is sent to us by your healthcare provider and required to ensure your clinical teams can identify you on the platform, authenticate yourself before submitting data into your Isla record, and contact you to do so.
Clinical visit data
Some of our partner healthcare providers send us visit information like appointment or attendance details so that we can automate clinical workflows and support clinicians in using the Isla platform and locating their patient records.
Personal health data
Either your clinician will capture this data directly into Isla, in which case they may allow you to opt-out at the point of capture, or you will be asked to make submissions yourself and will be able to opt out of submitting if you wish.
How do we use your personal data?
We will only use your personal data when the law allows us to as instructed by your healthcare provider. Please find in the table below a description of all the ways we plan to use your personal data. For the purposes below, Isla acts as a data processor, and so does not rely on a legal basis for processing this data. Instead, we are acting on express instructions from your healthcare provider, the data controller, so to understand their legal basis for processing your data you will need to visit their privacy policy.
| Purpose/Activity | Type of data |
| Identify you as a patient, contact you, and manage your record on Isla | Patient Identification & Demographics: – Full Name – Date of Birth – Sex – Postcode – Deceased Status (Indicator of whether the patient is living or deceased) System Identifiers: – NHS Number – Medical Record Number (MRN) / Hospital Number Contact Information & Preferences: – Phone Number(s) – Email Address(es) Contact Consent Preferences (e.g., opted in for SMS, email, or post) Clinical Context: – Healthcare Provider(s) (Primary Care Physician or Lead Consultant) – Associated Clinical Specialties (e.g., Cardiology, Oncology, Orthopaedics) |
| Manage your health conditions remotely | Digital Clinical Media: – Photographs (e.g., clinical images of wounds, skin lesions, or physical progress) – Videos (e.g., gait analysis, surgical recordings, or speech therapy sessions) – Sound Recordings (e.g., heart murmurs, respiratory sounds, or dictated clinical notes) Metadata & Documentation: – Form Responses (e.g., structured data from patient questionnaires or clinical assessments) -Media Annotations (Notes and observations saved specifically against images, videos, or audio files) |
Change of purpose
Your personal data will only be used for the purposes for which we collected it unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you, and we will explain the legal basis which allows us to do so. Please note, that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Disclosures of your personal data
We may share your personal data with other 3rd party sub-processors set out below for the purposes set out in the table:
| Purpose/Activity | Type of data | Third parties or sub-processors we may share your data with |
| Store your data | Your personal data (name, DoB) and your health identification data (NHS number, registered GP), medical and health data; e.g photos, videos, and notes | Google LLC – Locally based data centres |
| Notify you or clinicians of updates to the service | Your first name and email address | Our chosen email sending provider (Sparkpost) |
All third parties are requested to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with the data controller’s instructions. Controllers are aware of all sub-processors used and have carried out their own Data Privacy Impact Assessments on the relationships.
Sharing with other healthcare organisations involved in your care
Where your clinician identifies that it is clinically necessary for your continuing care, your registered healthcare provider may instruct us to make relevant clinical information – such as clinical visit data or personal health data captured on the Isla platform – available to General Practitioners or clinical staff at other healthcare organisations involved in your treatment.
This sharing takes place only at the instruction of, and under the legal basis established by, your registered healthcare provider as the data controller. Isla does not decide to share your data with another organisation on its own initiative. Any healthcare organisation receiving your data in this way is responsible for its own handling of that data once received, and you should refer to that organisation’s own privacy notice for further information.
Data security and storage
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorised way, altered, or disclosed. In addition, we limit access to your personal data to third parties. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
“Procedures have been established to address any suspected personal data breaches. We will notify you and any applicable regulator if a breach occurs, as required by law.
Images, videos, and sound recordings are never permanently stored on the device used to access our platform. They are captured directly from the browser and sent to our cloud database. Form data is cached on the device during a session to avoid loss of data and is deleted once a session is ended. Your data will be stored with our cloud storage provider. This service has server-side encryption, including strict key access controls and auditing.
All data and metadata are encrypted under the 256-bit Advanced Encryption Standard, and each encryption key is itself encrypted with a regularly rotated set of master keys.
Data retention
Where Isla acts as a data processor, we will only retain your personal data at the discretion of your healthcare provider (the data controller) to fulfill the purposes of the processing, while satisfying any legal, regulatory, or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation with respect to our relationship with you. Where your healthcare provider is an NHS Trust, retention periods are set by NHS England and can be seen here. In some circumstances, you can ask us to delete your data: see your legal rights below for further information. Also, in some instances, we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Your legal rights
You have several rights, outlined on the ICO website and below. Under data protection laws you have the right to:
Access your personal data:
- This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of your personal data: this enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data: this enables you to ask us to delete or remove personal data where there is no good reason for us to continue to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully, or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request for erasure for specific legal reasons, which will be notified to you, if applicable, at the time of your request.
- Please note that if you access our service using your NHS login details, the identity verification services are managed by NHS England. NHS England is the controller for any personal information you provided to NHS England to get an NHS login account and verify your identity, and uses that personal information solely for that single purpose. For this personal information, our role is a “processor” only, and we must act under the instructions provided by NHS England (as the “controller”) when verifying your identity. To see the NHS login’s Privacy Notice and Terms and Conditions, please click here. This restriction does not apply to the personal information you provide to us separately.
Objecting to processing your personal data:
- You have the right to object to the processing of your data when we are processing your personal data based on our legitimate interests (or that of a third party), and there is something about your particular situation that makes you want to object to the processing on this ground,d as you feel it impacts on your fundamental rights and freedoms. You also have the right to object to the processing of your data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information, which override your rights and freedoms.
- Request the restriction of processing your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios. If you want us to establish the data’s accuracy; where our use of the data is unlawful but you do not want us to erase it; where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data. We will provide it to you or a third party you have chosen. Your personal data is in a structured, commonly used, machine-readable format. Note that this right only applies to automated information. Which you initially provided consent for us to use, or where we used the information to perform a contract with you.
If you wish to exercise any of the rights set out above, please contact the DPO. Alternatively, contact us at data-request@isla.health.
Verification and approval process for data access requests
After contact, we may request specific information from you to help us confirm your identity. This will also ensure your right to access your personal data (or to exercise any of your other rights). This security measure ensures that your personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information concerning your request. This speeds up our response, and we aim to do this within seven days.
Where Isla is acting as a processor of your data, we will seek approval from your health provider as the data controller before being able to act on your request. The response to your request will be at the discretion of the data controller. If you make a request, we may ask you to confirm your identity. Then, will initiate this approval process within seven days. The response to your request from the data controller should be provided within a month of confirming your identity. It could take longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.
Interested to learn more?
Find out more about the great work we are doing and the impact we are having here.