Data Privacy Notice

Patient Information — Including AI-Assisted Clinical Service

Shilpa Dave Ltd | Version 2.0 | March 2026 | Replaces previous version

Who We Are

Shilpa Dave Ltd (‘We’, ‘Us’, ‘Our’) is committed to protecting your personal information, being transparent about how we use it, and respecting your privacy. We are the Data Controller for the personal data we hold about you as a patient.

Company

Shilpa Dave Ltd, registered in England, Company No. 10734587

Registered Address

Charles Rippin & Turner, Middlesex House, 130 College Road, Harrow, England, HA1 1BQ Clinical Address 59B High Street, Teddington, TW11 8HD

ICO Registration

ZA310560

Data Officer

A named lead practitioner holds the role of Data Officer for AI processing activities (details available on request from the Practice Manager)

Practice Manager

Giles Davies — practicemanager@privategp.org

Contact for Privacy Enquiries

pa@privategp.org | 0203 303 0326

What Personal Data We Collect

We collect and process the following categories of personal data:

Identity information: name, date of birth, gender
Contact details: address, telephone number, email address
Health and medical information (Special Category data): medical history, diagnoses, prescriptions, blood test results, investigation results, clinical notes
Financial information: payment card details (held securely by Stripe, not by us)
Communication records: emails, telephone records, consultation notes
Technical data: IP addresses, website usage data (cookies)

Our Practice Management Systems

Semble

Your patient records are stored within Semble, a UK-based, GDPR-compliant practice management system. Semble uses 256-bit encryption, UK-based servers, two-factor authentication, and SSL encryption. Each patient is assigned a unique reference code within Semble. We have a signed Data Processing Agreement with Semble.

Heidi Health — AI Consultation Scribe

We use Heidi Health, an AI-powered digital dictation tool, to document consultations. Heidi Health securely listens to the conversation between you and your clinician and produces clinical notes. All recordings are stored on UK-based servers. Heidi Health is registered with the MHRA and is integrated within Semble. We have a signed Data Processing Agreement with Heidi Health. Your consent to use Heidi Health will be sought before each consultation.

Use of Artificial Intelligence — Claude (Anthropic)

We use Claude, an AI assistant developed by Anthropic, to support a named lead practitioner (our Data Officer) in drafting clinical reports and supporting the interpretation of blood test results. This section explains what this means for your data.

What Claude Is Used For

Assisting the clinician to structure and draft clinical reports following blood test analysis
Providing interpretive frameworks to support (not replace) the clinician’s review of blood test values
Improving the consistency and quality of written clinical documentation

What Claude Is NOT Used For

Clinical triage or any form of emergency assessment
Making diagnoses or clinical decisions — all clinical decisions are made by your qualified GP
Direct communication with patients
Any processing not explicitly described in this notice

What Data Is Submitted to Claude

We operate a strict data minimisation protocol. Only the following information is ever submitted to Claude:

Your unique Semble reference code (a pseudonymous identifier — not your name, date of birth, or NHS number)
Blood test numerical values and reference ranges
Anonymised clinical context (for example: approximate age range, sex, broad clinical presentation) — never your name or any direct identifier

Your name, date of birth, address, NHS number, and all other direct identifiers are never submitted to Claude under any circumstances.

Your Lawful Basis for This Processing

We process this pseudonymised health data under UK GDPR Article 9(2)(h) — processing necessary for the provision of health care — and Article 6(1)(b) — performance of a healthcare contract. The Data Officer’s single-user access to Claude is governed by our internal AI Use Policy and this DPIA.

Where Claude Data Is Processed

Claude is operated by Anthropic PBC, based in the United States. Data submitted to Claude is processed on Anthropic’s servers. We take the following steps to protect your information: strict data minimisation (no direct identifiers), account privacy settings configured to minimise retention, and we are actively working to establish a formal Data Processing Agreement with Anthropic. In the interim, only pseudonymised data is ever submitted.

AI Output and Human Oversight

All outputs generated by Claude are reviewed, validated, and approved by the qualified clinician (Data Officer) before any clinical use. Claude’s outputs are assistive drafts only — they do not constitute clinical decisions and are never used without expert human review.

Your Right to Opt Out

You may request that your blood test data is not processed using Claude. In this case, reports will be prepared entirely by the clinician without AI assistance. To exercise this right, please contact pa@privategp.org or speak to reception.

How We Use Your Information

Processing appointments and bookings Article 6(1)(b) — contract performance

We use your personal data for the following purposes, under the lawful bases indicated:

Delivering clinical care and treatment

Article 6(1)(b) and Article 9(2)(h) — healthcare contract and provision

Billing and payment processing

Article 6(1)(b) — contract performance

AI-assisted report drafting (Claude)

Article 9(2)(h) — healthcare provision; strict data minimisation applied

AI consultation scribing (Heidi Health)

Article 9(2)(h) — healthcare provision; consent obtained separately

Communicating results and follow-up care

Article 6(1)(b) and Article 9(2)(h)

Sharing with other health professionals (with consent)

Article 9(2)(h) and Article 6(1)(a) — consent

Legal and regulatory compliance

Article 6(1)(c) — legal obligation

Marketing (only with your consent)

Article 6(1)(a) — consent (you may withdraw at any time)

Sharing Your Information

We will not share your personal data with third parties for marketing or advertising purposes. We may share data in the following circumstances:

With other healthcare professionals involved in your care (with your consent)
With our clinical systems suppliers (Semble, Heidi Health) under Data Processing Agreements
With Anthropic (Claude) — strictly as pseudonymised data as described above
With law enforcement or regulatory authorities where legally required
With billing and payment systems (Stripe) under appropriate contractual controls
As part of a legal process or business sale

Some of our suppliers, including Anthropic, may process data outside the UK/EEA. We take steps to ensure appropriate safeguards are in place.

Your Rights

Under UK GDPR, you have the following rights:

Right of Access

Request a copy of the personal data we hold about you

Right to Rectification

Request correction of inaccurate data

Right to Erasure

Request deletion of your data (subject to legal retention obligations)

Right to Restriction

Request that we limit processing of your data

Right to Portability

Request transfer of your data to you or a third party

Right to Object

Object to processing based on legitimate interests

Right to Opt Out of AI Processing

Request that Claude is not used in connection with your data (see above)

Right to Withdraw Consent

Withdraw consent where consent is the lawful basis

To exercise any right, contact us at pa@privategp.org or in writing to the Practice Manager at the clinic address. We may request proof of identity. We will respond within one month.

Data Retention

Clinical records are retained for a minimum of 8 years from the date of last treatment, or until the patient’s 25th birthday if records relate to a child, in accordance with NHS and GMC guidance for private practice. Financial records are retained for 7 years. Data submitted to Claude is subject to Anthropic’s data retention policies; we configure our Claude account to minimise retention wherever possible.

Automated Decision-Making

We do not use automated decision-making or profiling in our clinical practice. AI tools (Claude, Heidi Health) are used to support and assist qualified clinicians — all clinical decisions are made by a human practitioner.

Cookies

We use analytical and tracking cookies on our website (www.privategp.org) via Google and Bing services. These collect technical usage data. You may decline cookies on your first visit. A security cookie is used on our web portal for session security only.

Complaints

If you have a concern about how we handle your data, please contact us first at pa@privategp.org. If your concern is not resolved, you may complain to the Information Commissioner’s Office (ICO): ico.org.uk/concerns | 0303 123 1113 | ICO, 100 College Road, Harrow, HA1 1BQ.

Changes to This Notice

We may update this Privacy Notice periodically. Material changes will be communicated by email. This version supersedes all previous privacy notices. Version 2.0, March 2026.

Patient Consent

I confirm I have read and understood this Privacy Notice, including the section on AI-assisted clinical documentation. I consent to the collection and processing of my data as described above.

I wish to OPT OUT of AI-assisted report drafting using Claude: ☐ Yes ☐ No
Signed: ________________________________________ Date: _____________
Name (print): ___________________________________
Any other information: ___________________________