BacktoBetter – Privacy Policy

How HCML processes your personal data

HCML and BacktoBetter: Your Personal Data

Who HCML are and what we process:

HCML (Health & Case Management Ltd) have been instructed by your insurer, Aviva, to support your rehabilitation. We will collect personal data such as your name, address and contact details, details about your insurance policy, together with sensitive data – primarily regarding your health. From time to time, we may ask you about, or you may disclose to us, data in other special categories, for example, your sex life or sexual orientation, or your religious or political beliefs. We’ll also record calls to and from you.

Why we need it:

We need to store and use your personal data and health data for the purposes of: assisting you with your recovery and rehabilitation; and assisting Aviva in administering your Personal Medical Insurance policy. If we do ask for, or you disclose to us, data regarding other special categories apart from health it will only be stored and processed if it is relevant to these purposes – for example where your injury is affecting an aspect of your daily life, or a piece of information will assist us in coordinating your treatment. All our telephone calls are recorded for these purposes, as well as internal training, quality and administration purposes. We will ensure data we process is relevant and not excessive for these purposes, and we will not process data for any other purpose. As one of Aviva’s Rehabilitation suppliers, it is in our legitimate interests to process this data. We are permitted to process and share your sensitive data under the condition we are providing you health services and for no other reason, and are legally bound to keep your data confidential.

What we do with your data:

All your personal data remains in the UK, and in any event will not be transferred out of the EEA. We have a data protection framework in place to ensure the effective and secure processing, storage and transfer of your personal data. We will always process your data in accordance with the General Data Protection Regulations or other Data Protection legislation that may be in force. More information can be obtained by emailing

Who your data is shared with:

Your data will have initially been shared with us by your insurer, Aviva Health, as per your Personal Medical Insurance policy with them. We will add data you share with us directly, as well as data obtained from your treating practitioners, for example, Physiotherapists, Specialists, Radiographers and hospital/treatment facilities. We will share your personal and health data with your insurer, Aviva to support them in maintaining and administering your medical insurance cover, and with any treating practitioners to facilitate your referral to them. We will inform you of these companies at the time we make any referral to them. We will not share your information with third parties for any other reasons. As it is in our legitimate interests to process and share your data for these purposes, we are not relying on your consent to process your data. However, we will still ask for your agreement before sharing any information with third parties, as those third parties may not release the information we need to support you, without your agreement. In the event you do not provide your agreement for us to share and receive this data, or withdraw your agreement later, it is unlikely we will be able to continue your rehabilitation.

What are your rights?

  • You have the right to object to HCML processing your data
  • If at any point you believe the information we process about you is incorrect, you have the right to have it corrected
  • You also have the right to see the information we process about you
  • You may also have the right to have your data deleted
If you wish to raise a complaint about how we have handled your personal data, you can contact our Data Protection Officer who will investigate the matter. If you are not satisfied with our response or believe we are not processing your personal data in accordance with the law, you can complain to the Information Commissioner’s Office (ICO). Our data protection officer is Anthony Eeles and you can contact them at . HCML are Health & Case Management Ltd, registered at Melrose House, 42 Dingwall Road, Croydon CR0 2NE.