Privacy Notice - In-Ovo Fertility clinics Ltd
Introduction
In-OVO Fertility Clinics Ltd is committed to protecting the privacy of your personal data and to handling your personal data in a transparent and responsible manner in accordance with the UK GDPR, the Data Protection Act 2018 (DPA 2018) and the Data (Use and Access) Act 2025 (DUAA) as well as any other relevant Data Protection Regulations.
This Privacy Notice explains how and why we collect, process and disclose your personal data. It also outlines your rights in relation to your personal data. Please read the following carefully.
This Privacy Notice is current from13.04.26. From time to time we may make changes to our policy, processes and systems in relation to how we handle your personal data. We will update this Privacy Notice to reflect any changes. Those changes will be available on our website and in the clinic.
Controller Contact Details
In-OVO Fertility Clinics Ltd (Company Registration Number: NI616463, who is the data controller for the personal data we process all patients, unless otherwise stated.
All patient data collected in the Medical Record System is stored in the United Kingdom and is processed as per this Privacy Notice and only trained authorised staff can access patient’s data.
There are many ways you can contact us, including by phone, email, post and Patient Portal.
Main Clinic Postal Address
Main Clinic Postal Address
Thérapie Fertility
Portside Business Park
189 Airport Rd W, Belfast BT3 9ED
United Kingdom Contact number: +44 28 9620 7100 Email: info@in-ovo.co.uk
Company Registered Address
In-OVO Fertility Clinics Ltd
36-40 Ann Street, Belfast,
Northern Ireland, BT1 4EG
Data Protection Officer's Contact Details
Our Data Protection Officer is Cyrille Kuster. You can contact him at info@in-ovo.co.uk or via our postal address. Please address the envelope to ‘Data Protection Officer’.
The Type of Personal Data we Collect
- Personal data refers to information relating to an identified or identifiable person. It does not include data that has been anonymised and cannot be traced to an identified or identifiable person. We currently collect and/or process the following personal data:
- Identifying and Demographic Information: Identifying and Demographic Information: Full name, Date of Birth, gender, address, Passport number / Driver’s license, phone number(s) and email address, baby NHS number, Marriage Certificate.
- Medical and Health Information (Special Categories Personal Data): physical and mental health, test results, medical records provided by you, disabilities, family or individual health history, medical information relevant to your treatment at the clinic, blood type, ultrasound pictures, drugs prescriptions.
- Relationship and Sexual Information (Special Categories Personal Data): Sex life information, information regarding sexual orientation and relationship.
- Financial Information: Payment preference, bank account details, credit cards information through Global Payments (PCI compliant).
- Digital Images: Photograph used to perform visual confirmation of identification, CCTV footage, and also ultrasound, images of your eggs, embryos or sperm.
- Communication: Record of interaction between patients and clinic such as consultations, emails, messaging, phone calls and posts; Phone call recordings; voicemails; emails.
- Patient Preferences and Feedback: opinions and intentions disclosed during communication with clinic, satisfaction survey responses, complaints and compliments
- Electronic Device Information: IP Address and Cookies Information when visiting our website (for more information please see our Cookies Policy)
How We Get Your Personal Information
- Most of the personal information we process is provided to us directly by you from the following sources:
- Website Contact Form
- Website visits through cookies (See our Cookies Policy for more details)
- Phone or email queries
- Information you sent us on the Patient Registration Form and Health Questionnaires
- Information communicated to and by you throughout your treatment
- Information collected from testing and scanning you have throughout your treatment
- On some occasions we will also receive personal information indirectly from third parties such as:
- GP or other specialist referral
- Other Medical or corporate referral
- Test results related to you performed by a third party healthcare provider or laboratory”
Why We Collect Your Personal Information
Purposes
- To contact you in relation to a service you queried or to respond to your communication to us
- To contact you during your treatment with us regarding the medical aspect of care and also the administrative aspects of care including finance.
- This would also include the processing of Special Categories of Personal Data (Health Data, Sex life and Sexual Orientation Data)
- To ensure our staff have all information necessary to advise you of the best course of treatment.
- This would include the processing of Special Categories of Personal Data (Health Data, Sex life and Sexual Orientation Data)
- To carry out our obligations arising from any agreements entered into between you and us.
- For patient attending fertility services, all treatment record must be kept under the HFE Act 1990 & 2008 and data necessary to ensure identification and traceability of donated material must be kept to meet the legal requirements under the Human Fertilisation and Embryology (Quality and Safety) Regulations 2007.
- CCTV footage used for security reason including patients and staff safety
- To carry out statistical analysis to help us improve the quality of our services and to continue to perform at the highest standard. It may also support internal validation and research projects that aim to expand knowledge in the fields of fertility and embryology. In some cases, these projects may be undertaken in collaboration with approved third-party research partners. All data used in this process will be pseudonymised or anonymised, ensuring that you cannot be personally identified.
Legal Basis
- The processing is necessary for the performance of a contract or in order to take steps to enter into a contract with you.
- The processing is necessary for the performance of a contract with you.
- We will only process your Special Categories Personal Data after you have given us explicit consent to the processing of those personal data as part of your Medical Treatment with us.
- Processing is necessary for the performance of a contract with you.
- We will only process your Special Categories Personal Data after you have given us explicit consent to the processing of those personal data as part of your Medical Treatment with us.
- Processing is necessary for the performance of a contract with you.
- Processing is necessary for compliance with a legal obligation to which In-Ovo Fertility Clinics Ltd, as a HFEA Licenced Clinic, is subject to.
- You have given consent to the processing of your personal data (non-essential cookies information) through the Cookies Banner available on our website.
- The processing is necessary for the legitimate interests pursued by Thérapie Fertility in protecting their property and goods and
- maintaining your safety when using our buildings and environs, except where such interests are overridden by your interests or fundamental rights and freedoms.
- The processing is necessary for the legitimate interests pursued by Thérapie Fertility in assessing areas for business improvement as well as improvement of services offered. Except where such interests are overridden by your interests or fundamental rights and freedoms.
Special Categories Personal Data
As part of your treatment with In-Ovo Fertility Clinics Ltd, we will need to collect and process information concerning your health and concerning your sex life or sexual orientation. On some occasions, if required for treatment, we may also need to process information regarding your ethnicity and genetic data.
These information are considered Special Categories Personal Data under the UK GDPR and the Data Protection Act 2018. As such we will only process your Special Categories Personal Data after you have given consent to the processing of those personal data for the purpose of your medical treatment with us.
How We Store Your Personal Information
Your information is securely stored within our Patient Electronic Database System which also include the integration of our Web Patient Portal.
The number of paper records processed at Thérapie Fertility will be very limited and will be stored internally in our secured facilities.
All personal data will be kept as per In-Ovo Fertility Clinics Ltd Retention Policy. All information related to treatments will be kept in accordance with HFE Act 1990 & 2008. Any data necessary to ensure the identification and traceability of donated material will be kept for at least 30 years after clinical use as per the Human Fertilisation and Embryology (Quality and Safety) Regulations 2007.
Phone call recordings are securely stored at one of In-Ovo Third-Party Provider (see list of sub-processors below) and will be deleted after 3 months. Only In-Ovo authorised staff can access phone recordings and only for quality and training purposes.
CCTV recordings are securely stored in an authorised staff access controlled area managed directly by In-Ovo Fertility and are not accessible online. Only a very limited number of authorised In-Ovo Fertility staff can access those recordings and only with regards to security purposes and/or access request. CCTV recordings are deleted after 28 days.
Who We Share Your Personal Data With
In order to provide you with best quality of care as well as ensuring the compliance with legal obligation, some of your personal data will be shared on the need to know basis with the following third parties:
Testing laboratories or other healthcare providers that require your personal data as part of the provision of medical treatment;
Service providers, and other third party advisors (i.e. legal advisor, insurance) that have access to your personal data as a necessary and controlled part of the provision of service;
Other companies of the Thérapie Medical Ltd Group that have access to some of your personal data as a necessary and controlled part of the provision of service and clinic operation such as
Authorised staff of Thérapie Fertility Ltd registered in the Republic of Ireland as required
Authorised staff of from IT Services, Marketing Services and Financial Services also working within the Thérapie Medical Group.
Regulatory bodies such as but not limited to the HFEA (Prism reporting, etc) and the RQIA.
Mellowood Medical Inc. / Mogatrev LLC Maintenance and helpdesk support for Thérapie Fertility’s Electronic Medical Record System and other associated electronic systems. Storage Location is Belfast. Access only from Mellowood and Mogatrev are companies based in Canada. Barclays Provider and hosting of Phone Recording System used by In-Ovo Fertility Clinics Ltd, Server managemnet and data back up Processing location is within the UK. SPZ Lab A/S Medical Laboratory approved for testing of patient’s samples and associated personal data as requested. Data processing location is within the E.U. – Denmark Eurofins Biomnis Ireland Previously used Medical Laboratory approved for testing of patient’s samples and associated personal data as requested. (Not currently used by Thérapie Fertility) E.U. – Ireland Square Provider of compliant credit and debit card payment service.Processing location is within the UK. If you wish to obtain more information on third parties with whom your data may be shared, please contact our Data Protection Officer (dpo@therapiefertility.com). We will not transfer your personal data outside the United Kingdom / European Union except for your Electronic Consent Forms and Website Submission Information which will be stored by approved third party providers on a server located in the US (See List of Sub-Processors).
Testing laboratories or other healthcare providers that require your personal data as part of the provision of medical treatment;
Service providers, and other third party advisors (i.e. legal advisor, insurance) that have access to your personal data as a necessary and controlled part of the provision of service;
Other companies of the Thérapie Medical Ltd Group that have access to some of your personal data as a necessary and controlled part of the provision of service and clinic operation such as
Authorised staff of Thérapie Fertility Ltd registered in the Republic of Ireland as required
Authorised staff of from IT Services, Marketing Services and Financial Services also working within the Thérapie Medical Group.
Regulatory bodies such as but not limited to the HFEA (Prism reporting, etc) and the RQIA.
Mellowood Medical Inc. / Mogatrev LLC Maintenance and helpdesk support for Thérapie Fertility’s Electronic Medical Record System and other associated electronic systems. Storage Location is Belfast. Access only from Mellowood and Mogatrev are companies based in Canada. Barclays Provider and hosting of Phone Recording System used by In-Ovo Fertility Clinics Ltd, Server managemnet and data back up Processing location is within the UK. SPZ Lab A/S Medical Laboratory approved for testing of patient’s samples and associated personal data as requested. Data processing location is within the E.U. – Denmark Eurofins Biomnis Ireland Previously used Medical Laboratory approved for testing of patient’s samples and associated personal data as requested. (Not currently used by Thérapie Fertility) E.U. – Ireland Square Provider of compliant credit and debit card payment service.Processing location is within the UK. If you wish to obtain more information on third parties with whom your data may be shared, please contact our Data Protection Officer (dpo@therapiefertility.com). We will not transfer your personal data outside the United Kingdom / European Union except for your Electronic Consent Forms and Website Submission Information which will be stored by approved third party providers on a server located in the US (See List of Sub-Processors).
Your Data Protection Rights
- Under data protection law, you have rights including:
- Your right of access - You have the right to ask us for copies of your personal information. The clinic will conduct "reasonable and proportionate" searches for your data, and we may require further information to verify your identity or pinpoint specific records (e.g., specific treatment cycles), the response timeframe may be "paused" until that information is provided.
- Your right to rectification - You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
- Your right to erasure - You have the right to ask us to erase your personal information in certain circumstances. This right is not absolute as some data must be kept following other legal obligations such as HFE Act 1990 & 2008, Human Fertilisation and Embryology (Quality and Safety) Regulations 2007 and relevant HFEA Code of Practice.
- Your right to restriction of processing - You have the right to ask us to restrict the processing of your personal information in certain circumstances.
- Your right to object to processing - You have the right to object to the processing of your personal information in certain circumstances.
- Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.
- You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you. Please contact us at info@in-ovo.co.uk if you wish to make a request.
How To Complain
If you have any concerns about our use of your personal data, you can make a complaint to us at info@in-ovo.co.uk. We commit to acknowledge receipt of the complaint within 30 days and provide an outcome "without undue delay."
If you are unhappy with how we have used your data, you can also complain to the Information Commissioner’s Office (ICO). United Kingdom - Information Commissioner’s Office (ICO) Details:
ICO Helpline: +44 (0) 303 123 1113
Complaints Information on ICO Website:
https://ico.org.uk/make-a-complaint/data-protection-complaints/
For further information please visit https://ico.org.uk/