Q: Tax Strategy

Our overall tax strategy is to: • Comply with all relevant laws, rules, regulations, and reporting and disclosure requirements, wherever we operate • Pay the correct amount of tax at the right time • Identify, evaluate, monitor and manage tax, legal and regulatory risks • Apply professional diligence and care in the management of all risks, including tax matters • Take an appropriate and balanced approach when considering how to structure tax-sensitive transactions • Utilise tax reliefs and incentives where available in a manner which is consistent with applicable • law and regulations • Consider the tax impact in major or complex business decisions, for example acquisitions

Question 1

Website Privacy Statement

Accepted Answer

We are committed to ensuring that your privacy is protected. We strive to ensure your data is kept safe and that we comply with the legal obligations of the Data Protection Act 2018 (the ‘2018 Act’) and the EU General Data Protection Regulation (‘GDPR’). We will comply with the General Data Protection Regulation ((EU) 2016/679) (“GDPR”) unless and until the GDPR is no longer directly applicable in the UK, together with any national implementing laws, regulations and secondary legislation as amended or updated from time to time in the UK, and any successor legislation to the GDPR and the DPA (together “Data Protection Legislation”). We are the data controller of data you pass to us pursuant to this policy. Our Data Protection Officer can be contacted by getting in touch.

This Privacy Policy sets out how we collect personal information from you and how the personal information you provide will be processed by us. By visiting the website do not consent, please do not submit any personal data to us. We use Google Analytics to collect standard data and details of visitor behaviour patterns. We do this to find out information, such as numbers of visitors and how they navigate around our site. This information is collected in a way which does not identify anyone. We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website.

Question 2

What information do we hold and how will we use it?

Accepted Answer

Information you give: You may give us information about you by completing inquiry forms on the website. The information you give us may include your name, email address, address/location, and phone number. We will ask you to confirm that you give us permission to contact you.

We will retain this information while we are corresponding with you or providing services to you or to a Patient you represent. We will retain this information for as long as you or the Patient you represent is registered with us.

You may also give us your personal medical information that is stored securely in your patients notes on our medical operating system.

The Event will use your personal information for the following purposes only:

• to identify you when you contact us;
 • to help identify services and/or products which you could have from us or selected partners;
 • to help administer, and contact you about improved administration of any services and products we have provided, provide now or in the future;
 • to carry out marketing analysis and customer profiling, to conduct research, including creating statistical information;
 • to help to prevent and detect fraud or loss;
 • to contact you in any way (including mail, email, telephone, or text) about products and services offered by us and/or selected partners unless you have previously asked us not to do so;
 • to keep you up to date with our Membership Plans, under which we will give you Membership information and details of discounts and offers negotiated on behalf of our Members.

We may allow other people and organisations to use information we hold about you if we have been legitimately asked to provide information for legal or regulatory purposes or as part of legal proceedings or prospective legal proceedings. We will, however, always use every reasonable effort to ensure sufficient protections are in place to safeguard your personal information.

We may monitor and record communications with you (including phone conversations and emails) for quality assurance and compliance reasons.

Where you give us information on behalf of someone else, you confirm that you have provided them with the information set out in these provisions and that they have not objected to such use of their personal information. Where you give us sensitive data about yourself or another person (such as health details) you agree (and confirm that the other person has agreed) to our processing such information in the manner set out in these provisions.

Question 3

Cookies

Accepted Answer

The Website uses cookies to distinguish you from other users of the website. Cookies are useful because they allow a website to recognise a user’s device. You can choose to accept or decline cookies. We don’t hold any information from these.

Where we are processing personal data we have obtained via the website on the basis of having obtained consent from you, you have the right to withdraw your consent to the processing of your personal data at any time. If you would like to withdraw your consent or prefer not to receive any of the above-mentioned information (or if you only want to receive certain information from us) please let us know by contacting us via the webpage. Please bear in mind that if you object, this may affect our ability to carry out the tasks above for your benefit.

If you wish to have your information removed from our database or if you do not want us to contact you for marketing purposes, please let us know by contacting us via the website and we will take steps to ensure that this information is deleted as soon as reasonably practicable.

We will not share, sell or distribute any of the information you provide to us (other than as set out in this policy) without your prior consent unless required to do so by law.

Question 4

Third-Party Sites

Accepted Answer

Our website may contain links to third-party websites, including websites via which you are able to purchase products and services. They are provided for your convenience only and we do not check, endorse, approve or agree with such third-party websites nor the products and/or services offered and sold on them. We have no responsibility for the content, product and/or services of the linked websites. Please ensure that you review all terms and conditions of website use and the Privacy Policy of any such third-party websites before use and before you submit any personal data to those websites.

Question 5

How Safe is your Information?

Accepted Answer

Where we have given you (or where you have chosen) a password which enables you to access certain parts of the website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Protecting your security and privacy is important to us and we make every effort to secure your information and maintain your confidentiality in accordance with the terms of the Data Protection Legislation. The website is protected by various levels of security technology, which are designed to protect your information from any unauthorized or unlawful access, processing, accidental loss, destruction, and damage.

We will do our best to protect your personal data but the transmission of information via the Internet is not completely secure. Any such transmission is therefore at your own risk.

No personal medical information is stored on this website. We use a secure electronic patient record system to store all personal medical information. Access to patient medical records is strictly monitored and secured. Our Medical system, Meddbase (MMS), is NHS Data Security and Protection Toolkit (DSP Toolkit) compliant, ISO27001 certified and follows the strict information handling requirements of these standards.

The practice may share information with other professionals involved in your medical care, for example to enable a referral to a specialist, with your consent.

Question 6

Your Rights in Respect of your Data

Accepted Answer

If any of the information you provide to us via the website changes, please let us know as soon as possible so that we can make the necessary changes to the information we hold for you on our database. If you wish to make any changes to your information, please contact us via the website.

If you wish to access or rectify the information we hold about you or request that such information be transmitted directly to another data controller, please contact us. We shall process your request to access your information within one month of receipt, or we'll let you know within that timeframe if we need more information from you. We will process your request free of charge.

To request that your information is deleted or if you wish to restrict or object to the processing of your information, please contact us. If you have any complaints about our use of your personal data, please contact us. You also have the right to complain to the relevant supervisory authority in your jurisdiction. In the UK, the supervisory authority is the Information Commissioner's Office. Contact details for the ICO can be found at https://ico.org.uk/.(https://ico.org.uk/)

If you have any further queries or comments on our Privacy Policy, please contact us.

We also welcome your views about our website and our Privacy Policy.

Question 7

Disclosure of your Information

Accepted Answer

Please note we may need to disclose your personal information where we:

• Sell any or all our business or assets or we buy another business or assets in which case we may disclose your personal data to the prospective buyer or seller
 • Are under a legal duty to comply with any legal obligation or to enforce or apply our terms and conditions; or
 • Need to disclose it to protect our rights, property or the safety of our customers or others, including the exchange of information with other companies, organizations and/or governmental bodies for the purposes of fraud protection and credit risk reduction

Question 8

Tax Strategy

Accepted Answer

Our overall tax strategy is to:
​
 • Comply with all relevant laws, rules, regulations, and reporting and disclosure requirements, wherever we operate
 • Pay the correct amount of tax at the right time
 • Identify, evaluate, monitor and manage tax, legal and regulatory risks
 • Apply professional diligence and care in the management of all risks, including tax matters
 • Take an appropriate and balanced approach when considering how to structure tax-sensitive transactions
 • Utilise tax reliefs and incentives where available in a manner which is consistent with applicable
 • law and regulations
 • Consider the tax impact in major or complex business decisions, for example acquisitions

Question 9

Tax Planning

Accepted Answer

The Group will not engage in artificial transactions where the sole purpose of which is to reduce tax.  However, the Group will consider undertaking a transaction in a way that gives rise to tax efficiencies providing this is aligned to the Group’s commercial strategy and complies with the associated tax legislation.  The Group will seek advice from external advisors where the existing Finance team does not have the appropriate level of tax knowledge and experience to ensure compliance with existing tax legislation.

Question 10

Tax Risks and Working with HMRC

Accepted Answer

The Group’s strategic aim is to be low risk in respect to tax compliance and to have a strong relationship with HMRC.   The Group seeks to achieve this aim through submission of all UK Tax returns on a timely basis and paying the appropriate amount of tax at the right time.