About PAM Life
PAM Life is the Data Controller and has appointed James Murphy as its Data Protection Officer. Our Registered Office is Holly House, 73-75 Sankey Street Warrington Cheshire WA1 1SL.
Who is the Policy for?
This policy is information for members that we hold information for or are about to hold their information. Members are provided these services and information on behalf of our Clients. They are mostly our members but we also provide private treatment in this case we hold data for you the individual. PAM Group are committed to ensuring we hold your data securely this policy explains:
- What we hold?
- Why we hold it?
- How long we hold it for?
PAM Group holds “Personal and Special Information” as defined by the GDPR and Data Protection Regulations. We treat our responsibilities very seriously as an organisation and as individuals we will always treat your information as important and ensure that we protect its use, access and accuracy. PAM Life is registered with the Information Commissioners Office Registration Number ZA56720.
Why do we hold your data?
Personal Data - PAM Life provides health and wellbeing services and advice to our clients and their members. Health members gain benefits in living a more positive and healthier life and our clients obtain benefits as a result.
PAM Life holds personal data this is limited in order to allow and administer your registration and account details. Members receive the services as long as our clients retain and pay for the services. No personal data is provided to our clients other than in an anonymous form for trend and statistical reporting purposes.
Special Data - Where a member completes any health and wellbeing assessment or is supported by a PAM Life clinician as part of their programme, Special Data your health information is captured by PAM Life. This information is treated as clinical confidential and will never be disclosed to anyone without your consent. All health data is stored in individual clinical files and is accessed and used by PAM Life clinicians in providing advice and services to members and our clients.
PAM Life employs specialist clinicians who provide advice and medical treatment. These include doctors, specialist nurses, physiotherapists, counsellors, psychologists, psychiatrists, nutritionists, physiologists, wellbeing advisors legal advisors and debt advisors.
We hold your health records; these are medical and personal records that must be held for your safety and wellbeing at work. Authorised medical professionals may only hold occupational health records as set out in the Data Protection Act (2018) s 204.
We process your data for this purpose in compliance with:
Where we provide occupational health services and or Employee Assistance Programme (EAP) services, we hold information about our clients employees this will include personal details E.G. Name, Home address, Date of Birth, Job details and medical records. We need this information to be able to provide accurate advice to you and your employer ensuring that work does not damage your health and you are fit for the work you do.
PAM use the information held in the delivery of our services.
1. We need personal information e.g. name address, date of birth in order to identify and verify the correct person and in some cases where we need to communicate with your health care provider this is the standard identification information used with the NHS.
2. We need your personal contact details email to assist us communicating with you when booking appointments.
3. We need and will create medically confidential information so that our clinicians can provide professional advice based on your health fitness and wellbeing.
4. We operate a secure occupational health IT system this requires any member of our service including employees referred or managers making referrals to be registered as an employee within our system.
All medical information is held securely and only access by PAM Life workers.
PAM Life process your personal and special data (Health records) on the basis that each member has;
Under Article 6(1)(a) of GDPR: has given consent to the processing of their personal data for one of more purposes and under GDPR Article (9)(2)(a) has given explicit consent for the processing of their special data health records whilst they remain a member or have access to the service.
We do not and will never sell your information to anyone else.
We do not share your information with anyone else. Any information shared with clients is anonymous with no personal information.
We will not use your information to sell you anything or promote any services that are not related to the provision of occupational health or healthcare services or EAP services.
During the time that PAMLife provides members and clients with our service we will create and add our records to your health file. If our Client leaves PAMLife your health file and data captured by PAMLife will be destroyed. PAMLife will not retain a copy of your records after a member or client leaves us or stops paying for the service.
PAM Group will only use qualified clinicians when we provide advice or services to you or your employer our clinicians are regulated and authorised by, Nursing Midwifery Council, General Medical Council, Health Care Protection Council, and British Association of Counselling and Psychotherapy.
The UK Data Protection Regulations are specific about the treatment of personal and special data (unless exemptions apply), you have the right to:
- To ask us not to process your personal data for marketing purposes
- To prevent the processing of any personal data that is causing or is likely to cause unwarranted and substantial damage or distress to you or another person
- To have any inaccurate or incomplete data corrected
- To restrict or object to the processing of your data and fro your data to be erased under certain circumstances.
- To receive a copy of your records by making a Subject Access Request in writing. To request a copy of your Data Please submit your request to the Data Controller, PAMLife, Holly House, 73-75 Sankey Street, Warrington, Cheshire, WA1 1SL. Please contact the Subject Access Request team: email@example.com
- To make a complaint about the way that your personal data is being processed by contacting the Information Commissioners Office (https://ico.org.uk )
If you have any concerns in relation to the security of our site or your personal data contained within it.
All information you provide to us is stored on secure servers. All special Data is encrypted and has additional cyber security measures taken to protect your privacy. Your registration process provides your unique identity profile to your data. No one outside PAMLife can access your data our Client who may be your employer cannot access your data Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site or applications, you are responsible for keeping this password confidential. Please do not to share a password with anyone.
When you send information to us by email, please bear in mind that the transmission of information over the internet is not completely secure, unless the information is encrypted. Whilst we take all reasonable steps to protect your personal data on our systems, we cannot guarantee the security of any data you choose to email to us, so, please be aware that sending us your personal data via email is at your own risk. Once we have received your information, we will use strict procedures and security controls to ensure its ongoing confidentiality and protection.
With regards to each of your visits to our site we may automatically collect the following: technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); plans you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs); and methods used to browse away from the page and any phone number used to call our customer service numbers.
This website uses Mouseflow: a website analytics tool that provides session replay, heatmaps, funnels, form analytics, feedback campaigns, and similar features/functionality. Mouseflow may record your clicks, mouse movements, scrolling, form fills (keystrokes) in non-excluded fields, pages visited and content, time on site, browser, operating system, device type (desktop/tablet/phone), screen resolution, visitor type (first time/returning), referrer, anonymized IP address, location (city/country), language, and similar meta data. Mouseflow does not collect any information on pages where it is not installed, nor does it track or collect information outside your web browser. If you'd like to opt-out, you can do so at https://mouseflow.com/opt-out. If you'd like to obtain a copy of your data, make a correction, or have it erased, please contact us first or, as a secondary option, contact Mouseflow at firstname.lastname@example.org.
For more information on Mouseflow and GDPR, visit https://mouseflow.com/gdpr/.
PAM Life can be provided in 2 ways;
a) Paid for by a client, usually an employer, retailer or organisation that a member belongs to.
b) Paid for by a member who personally and individually subscribes to the service.
In the event that a client or member ceases to pay for the service or commits any fraud, their access to the service will be terminated.
PAMLife may offer service incentives such as moneyback offers in the event a member terminates their membership. Any money to be repaid will be paid within this period 28 days of the notice to take up the moneyback offer.
1. Complaints Policy Statement
is committed to providing a good standard of quality services to service users and organisations
will take seriously any concern or complaint and will look into it promptly, for resolution as quickly as possible
recognises that all service users and organisations:
- have the right to raise concerns or complaints about our services
- have access to clear information on how to voice complaints and concerns
concerns and complaints procedure is open to everyone who receives or requests a service from PAM Life and people acting on their behalf
will keep a register of all complaints, which will be reviewed regularly
complaints procedure will be part of the process of monitoring the quality, effectiveness and non-discriminatory nature of its services
All staff members are required to read, understand and comply with this policy and its procedures
We always use reasonable endeavours to ensure that our services are trouble-free
We will use reasonable endeavours to remedy problems with the services as quickly as is reasonably possible and practical.
PAM Life Limited strives for high standards in service delivery and welcomes feedback from individuals, users of our services, stakeholders, and anyone who works with us, on all aspects of our services. Such feedback is invaluable in helping us evaluate and improve our work.
Our objectives are to:
Ensure everyone knows how to make a complaint and how a complaint will be handled
Ensure that complaints are dealt with consistently, fairly and sensitively within clear time frames
Provide individuals with a fair and effective way to complain about our work
Ensure that complaints are monitored to improve our services
In handling with your complaint PAM Life Limited will ensure that we:
Listen carefully to complaints and treat complaints as confidential, where possible
Record, store and manage all complaints accurately and in accordance with the Data protection Act
Investigate the complaint fully, objectively and within the stated time frame
Notify the complainant of the results of the investigation and any right of appeal
Inform the complainant of any action that will be implemented in order to ensure that there is no re-occurrence
Report on an annual basis, the number of complaints received, the outcomes and any actions taken.
Definition of a complaint
A complaint is any expression of dissatisfaction by an individual, whether justified or not.
An individual may make a complaint if they that PAM Life Limited has:
Failed to provide a service or an acceptable standard of service or made a mistake in the way the service was provided
Failed to act in a proper way
Provided an unfair service
Concern or Complaint
It is important to establish the difference between a concern and a complaint. Taking informal concerns seriously at the earliest stage will reduce the likelihood of them developing into formal complaints.
If you have any concerns about our work please do inform us as soon as possible, so they can quickly understand your concerns and try to put things right.
If you are not happy with the response to your concern and/or you want to make a formal complaint please follow the procedure below.
3. Complaints Procedure
Stage One - Complaint
Individuals wishing to make a complaint should contact us by email at email@example.com
The complaint should include the complainants name, the nature and date of the complaint and how they want to see it resolved.
The complainants will receive an acknowledgement within 3 working days of receipt of a signed complaint.
Stage Two - Investigation
All complaints will be dealt with by dedicated members of the PAM Life team. If they need to meet with the complainant, they will do so within seven working days of receiving the complaint.
Complaints will be fully investigated, and a response provided to the complainant within ten working days by the investigator.
The complainant will receive confirmation of the outcome of any investigation and any recommendations/remedies made.
Where the complaint is upheld an apology should be offered.
Occasionally investigations may take longer, particularly if the complaint is complex. Should this be the case a holding response will be sent after ten working days and a final date given for a conclusion to be reached.
If an individual remains dissatisfied with the outcome from Stage Two they can appeal within fourteen working days of the date of the outcome and progress to Stage Three.
Stage Three - Appeal
If the complaint cannot be resolved to the complainants satisfaction at stage two, or if the dedicated member of the PAM Life team feels that the complaint is of a very serious nature then it will be referred to a senior executive.
The senior Executive will acknowledge receipt within three working days, they will review the Stage Two investigation and recommend one of the following actions within ten working days (from the date the complainant stated they wanted to take the complaint to stage 3):
Uphold the action taken at Stage Two
Make changes to the Stage Two recommendation/actions
The complainant should be informed in of the outcome of stage three, the decision reached about this complaint will then be final but other options available to the complainant (as listed below) should be detailed in the response.
If after PAM Life Limited has been through the three stages and the complainant is still not satisfied with the result, they should be advised that there is no further right of appeal with PAM Life Limited but they could approach any of the following agencies for advice:
Citizens Advice Bureau
This should be done within one month of receiving the outcome from the appeal.
Complaints received anonymously will be recorded and considered, but action may be limited if further information is required to ensure a full and fair investigation.
4. Data Protection
To process a complaint PAM Life Limited will hold personal data about the complainant, which the individual provides, and which other people give in response to the complaint. We will hold this data securely and only use it to address the complaint. The identity of the person making the complaint will only be known to those who need to consider the complaint and will not be revealed to other people or made public. However, it may not be possible to preserve confidentiality in some circumstances, for example, where relevant legislation applied or allegations are made which involve the conduct of third parties.
Complaints are an important tool which, alongside with other forms of user feedback, will allow us to learn about the services we provide. They provide a useful source of information about how individuals see our services and how we are serving them. To ensure we can learn from complaints the following data will be collected:
Name of person handling with the complaint
Date of complaint and response
Nature of complaint
Action(s) taken/recommendations made in response to the complaint Lessons learnt
Complaints information will be considered on a regular basis by the Management Team and wherever possible the data will be used to improve and develop the service.