In this Privacy Notice we use "we", "us", "our" , "p4 Fertility", "Aarna private limited" or "Agrni promotions" to refer to p4 Fertility, Aarna private limited and Agrni promotions. We will advise you in our communications with you of the specific company within the p4 Fertility Healthcare group of companies which is making decisions about the use of your personal information.

We may collect information about you when you request any information about us or our services, submit your personal details and/or complete any forms on the website, contact us via social media or use our live chat facilities on our website. This information will come directly from you. In limited circumstances we may also receive information about you on your behalf, such as where you have asked a family member to contact us, or if your GP contacts us directly. Personal information, or personal data, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may also collect special categories of personal information about you. This includes personal information relating to details about your health, and genetic and biometric data, race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, or trade union. If you provide personal information to us about other individuals (including medical or financial information) you should inform the individual about the contents of this Privacy Notice. We will process such information in accordance with this Privacy Notice. We have set out details below about the types of personal information we are likely to collect and use about you when you use our websites or interact with us via social media. The extent of the information we collect and use will depend on what information you choose to provide to us or what information is provided to us on your behalf. Personal data general information you provide, such as your name, address, contact details, date of birth, gender and next of kin information relating to appointments information regarding your ability to pay for services and payment information information regarding your experiences with us information you provide in surveys or feedback information relating to any complaint you may make against us or our staff information about your areas of interest, if you are signing up to receive our update emails information you send in any job application or speculative enquiries in relation to job vacancies, such as employment history or qualifications information when you visit our websites. p4 Fertility uses Google Analytics and cookies in order to improve our service and user experience and to analyse how the website is used. Aside from the approximate location (IP address), the information collected by Google Analytics is anonymous traffic data including browser information, device information, and language. The collected information is used to provide an overview of how people are accessing and using p4 Fertility's websites. For more information about our use of cookies, please see our cookie policy. Special categories of personal data details of your current or former health condition, including information about medication, lifestyle and other information that may be relevant to your health e.g. employment history, family conditions; race; ethnicity; sex life or sexual orientation, religious or philosophical beliefs information relating to criminal convictions (including offences and alleged offences and any court sentence or unspent criminal conviction) in limited circumstances, we may process other sensitive personal information including details of your political opinions; and trade union membership, for example, where it is relevant to your health or social history

We process your personal information for the purposes set out in this Privacy Notice. We will only use your personal data when the law allows us to. Each time we use your data we must have a legal justification to do so. The particular justification will depend on why we are using your data. When the information that we process is classed as "special categories of personal information", we must have a specific additional legal justification in order to use it as proposed. Generally, we will rely on the following legal grounds for processing your personal data: Taking steps at your request so that you can enter into a contract with p4 Fertility and/or a clinician to receive healthcare services from us, or for the purposes of that contract. If we have a contract with you, we will process your personal information in order to fulfil that contract (that is, to provide you with our products and services). Taking steps at your request so that you can enter into an employment contract with p4 Fertility, or for the purposes of that contract. We have an appropriate business need (a 'legitimate interest') to process your personal information and those interests are not overridden by your privacy rights. We will rely on this for activities such as administration and service improvement. Further details of those legitimate interests are set out in more detail below. We may process special categories of personal information about you because: It is necessary for the purposes of preventive or occupational medicine, providing you with medical diagnoses, providing you with healthcare or for the management of our healthcare services. It is necessary for reasons of substantial public interest, such as insurance-related purposes or for preventing or detecting fraud. The use is necessary in order for us or a third party to establish, exercise or defend our legal rights. You will find further details of our "legal grounds" for each of our processing purposes set out below. Providing healthcare and related services Legal grounds: The use is necessary to provide you with healthcare and other related services. The use is necessary for fulfilling our contract with you for the delivery of healthcare. The use is necessary for fulfilling our legitimate interests (e.g. an appropriate business need) and those interests are not overridden by your privacy rights. Additional legal grounds for special categories of personal data: The use is necessary to provide you with healthcare and other related services. The use is necessary to protect your vital interests where you are physically or legally incapable of giving consent. The use is necessary for an insurance-related purpose. The use is necessary to protect your vital interests where you are physically or legally incapable of giving consent. Administration and management of healthcare services (such as maintaining records, receiving professional advice) Legal grounds: The use is necessary to provide you with healthcare and other related services. The use is necessary to comply with a legal or regulatory obligation. The use is necessary for fulfilling our contract with you for the delivery of healthcare. The use is necessary for fulfilling our legitimate interests (e.g. an appropriate business need) and those interests are not overridden by your privacy rights. Additional legal grounds for special categories of personal data: The use is necessary for the purposes of preventive or occupational medicine, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services. The use is necessary in order for us or a third party to establish, exercise or defend our legal rights. Service improvement, evaluation and audit (in order to improve the healthcare services that we provide) Legal grounds: The use is necessary for compliance with a legal or regulatory obligation. The use is necessary to provide you with healthcare and other related services. The use is necessary for fulfilling our legitimate interests (e.g. an appropriate business need) and those interests are not overridden by your privacy rights. Additional legal grounds for special categories of personal data: The use is necessary for the purposes of preventive or occupational medicine, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services. You have given us your explicit consent. Communicating with you and resolving any queries or complaints that you might have. Communicating with any other individual that you ask us to update about your care. Legal grounds: The use is necessary to provide you with healthcare and other related services. The use is necessary for compliance with a legal obligation. The use is necessary for fulfilling our contract with you for the delivery of healthcare. The use is necessary for fulfilling our legitimate interests (e.g. an appropriate business need) and those interests are not overridden by your privacy rights. You have given us your explicit consent. Additional legal grounds for special categories of personal data: The use is necessary for the purposes of preventive or occupational medicine, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services. The use is necessary in order for us or a third party to establish, exercise or defend our legal rights. You have given us your explicit consent. Complying with our legal and regulatory requirements Legal grounds: The use is necessary for compliance with a legal obligation. The use is necessary for fulfilling our legitimate interests (e.g. an appropriate business need) and those interests are not overridden by your privacy rights. You have given us your explicit consent. Additional legal grounds for special categories of personal data: The use is necessary for the purposes of preventive or occupational medicine, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services. The use is necessary in order for us to establish, exercise or defend our legal rights. You have given us your explicit consent. Clinical research and development Legal grounds: The use is necessary to provide you with healthcare and other related services. The use is necessary for compliance with a legal obligation. The use is necessary for fulfilling our legitimate interests (e.g. an appropriate business need) and those interests are not overridden by your privacy rights. You have given us your consent. Additional legal grounds for special categories of personal data: The use is necessary for the purposes of preventive or occupational medicine, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services. We need to use the information for reasons of substantial public interest. The use is necessary for reasons of public interest in the area of public health, such as ensuring high standards of quality and safety of health care. The use is necessary for public interest or scientific research purposes so long as it is subject to appropriate safeguards. You have given explicit consent. Safeguarding purposes (for example, in order to ensure the health and safety of an individual) Legal grounds: The use is necessary for compliance with a legal obligation. We need to use the information to protect your vital interests or the vital interests of a third party. The use is necessary to provide you with healthcare and other related services. Additional legal grounds for special categories of personal data: We need to use the information to protect your vital interests or the vital interests of a third party and you or the third party are physically or legally incapable of giving consent. We need to use the information for reasons of substantial public interest, such as the use being necessary in protecting an individual from neglect or physical, mental or emotional harm and protecting the physical, mental or emotional wellbeing of an individual. You have given us your explicit consent. Preventing and investigating fraud. This might include sharing your personal information with third parties such as the police or fraud prevention agencies, or carrying out fraud, credit, anti-money laundering and other checks Legal grounds: The use is necessary to provide you with healthcare and other related services. The use is necessary for fulfilling our legitimate interests (e.g. an appropriate business need) and those interests are not overridden by your privacy rights. Additional legal grounds for special categories of personal data: We need to use the information for reasons of substantial public interest. Carrying out marketing activities and providing marketing information to you Legal grounds: The use is necessary for fulfilling our legitimate interests (e.g. an appropriate business need) and those interests are not overridden by your privacy rights. You have given us your consent. For employment and pre-employment purposes, such as considering job applications from you, carrying out pre-employment checks and entering into an employment contract Legal grounds: Taking steps at your request so that you can enter into an employment contract with BMI Healthcare, or for the purposes of that contract. We have a legal or regulatory obligation to use your personal information. The use is necessary for fulfilling our legitimate interests (e.g. an appropriate business need) and those interests are not overridden by your privacy rights. You have provided your consent to our use of your personal information. Additional legal grounds for special categories of personal data: We need to use the information for reasons of substantial public interest. It is necessary for the management of our healthcare services. It is information that you have made public. You have provided your explicit consent.

From time to time, we may share your personal information with others. We will keep your personal information confidential and only share it with those listed below for the purposes explained in the previous section. Sharing within the p4 Fertility, Aarna private limited and Agrni promotions group of companies We may share your information with other companies in the p4 Fertility, Aarna private limited and Agrni promotions group, for example, in order to provide you with healthcare services or progress your employment application. Sharing with third parties We may share information with the following third parties: Clinicians or other healthcare professionals involved in your treatment Other staff involved in your healthcare, such as receptionists, secretaries and administrative assistants Organisations from which you are receiving healthcare services, such as your GP or dentist Third parties who are involved in your healthcare, such as insurers Other private sector healthcare providers The Private Healthcare Information Network Third parties involved in research or audit projects NHS organisations, including NHS Resolution, NHS England, Clinical Commissioning Groups, NHS Foundation Trusts, NHS Trusts, or the Department of Health as well as third parties that have contractual relationships with such NHS organisations Government bodies such as the Home Office and HMRC Regulators, such as the ICO, the Care Quality Commission, Health Inspectorate Wales, and Health Improvement Scotland The police and other third parties where reasonably necessary for the prevention or detection of crime Anyone that you have asked to communicate with us on your behalf, or have named as an emergency contact, such as your representative, next of kin or carer Debt collection agencies Our insurers Our third party services providers and advisers, such as IT suppliers, actuaries, auditors, lawyers, marketing agencies, document storage and management providers and tax advisers Preferred partners for credit agreements Credit referencing agencies Any third parties involved in the sale, transfer or disposal of all or a part of our business We may communicate with these third parties in a variety of ways including, but not limited to, email, post, fax and telephone.

Under certain circumstances, you have rights under data protection laws in relation to any personal information that we hold about you. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. We try to respond to all requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. If you wish to exercise any of the rights set out below, please contact the DPO using the contact details set out below. Details of your rights are set out below. The right to access your personal information You are usually entitled to a copy of the personal information we hold about you and details about how we use it. Your information will usually be provided to you in writing, unless otherwise requested. If you have made the request electronically (e.g. by email) the information will be provided to you by electronic means where possible. You are entitled to the following under data protection law. Under data protection law we must usually confirm whether we have personal information about you. If we do hold personal information about you we usually need to explain to you: The purposes for which we use your personal information. The types of personal information we hold about you. Who your personal information has been or will be shared with, including in particular organisations based outside the EEA. If your personal information leaves the EU, how we make sure that it is protected. Where possible, the length of time we expect to hold your personal information. If that is not possible, the criteria we use to determine how long we hold your information for. If the personal data we hold about you was not provided by you, details of the source of the information. Whether we make any decisions about you solely by computer and if so details of how those decision are made and the impact they may have on you. Your right to ask us to amend or delete your personal information. Your right to ask us to restrict how your personal information is used or to object to our use of your personal information. Your right to complain to the Information Commissioner's Office. We also need to provide you with a copy of your personal information. If you are a patient of p4 Fertility and you wish to request details of or a copy of your medical records, please contact the hospital at which you have received the care and treatment. For all other requests for any personal information we may hold (such as employment records, if you are an ex-employee) please direct your request to the Data Protection Officer, using the contact details below. The right to request correction of your personal information We take reasonable steps to ensure that the personal information we hold about you is accurate and complete. However, if you do not believe this is the case, you can ask us to update or amend it. The right to request erasure of your personal information In some circumstances, you have the right to request the erasure of the personal information that we hold about you. This is also known as the 'right to be forgotten'. However, there are exceptions to this right and in certain circumstances we can refuse to delete the information in question. In particular, for example, we do not have to comply with your request if it is necessary to keep your information in order to perform tasks which are in the public interest, including public health, or for the purposes of establishing, exercise or defending legal claims. The right to object to the processing of your personal information In some circumstances, you have the right to object to the processing of your personal information. However, there are exceptions to this right and we do not have to "pause" the processing of your information where, in particular, if it is necessary to keep your information in order to perform tasks which are in the public interest, including public health, or for the purposes of establishing, exercise or defending legal claims. The right to request a transfer of your personal information In some circumstances, we must transfer personal information that you have provided to us to you or (if this is technically feasible) another individual/ organisation of your choice. The information must be transferred in an electronic format. The right to object to marketing As detailed in the 'marketing' section above, you can ask us to stop sending you marketing messages at any time and we must comply with your request. You can do this by contacting the DPO. The right not to be subject to automatic decisions (i.e. decisions that are made about you by computer alone) You have a right to not be subject to automatic decisions (i.e. decisions that are made about you by computer alone) that have a legal or other significant effect on you. The right to withdraw your consent You have the right to withdraw your consent where we rely upon this as a legal ground for processing your information. You can do this by contacting our DPO. The right to complain to the Information Commissioner's Office You have the right to complain to the Information Commissioner's Office if you are unhappy with the way that we have dealt with a request from you to exercise any of these rights, or if you think we have not complied with our legal obligations under data protection law. More information can be found on the Information Commissioner's Office website: https://ico.org.uk/ Making a complaint will not affect any other legal rights or remedies that you have.

We will only keep your personal information for as long as reasonably necessary to fulfil the relevant purposes set out in this Privacy Notice and in order to comply with our legal and regulatory obligations.

We (or third parties acting on our behalf) may transfer, store or process information about you in countries outside the EEA. Where this is the case we take the required steps to ensure that your personal information is protected.

1.  What This Section Tells YouP4 Fertility, P4 Clinic uses an in-house, purpose-built AI-enabled patient record system to create and maintain your clinical notes. To power this system, we may audio record your consultation with your clinician. This page explains what we record, why we do it, how your recording is protected, and your rights.We are committed to being fully transparent about this process. If you have any questions, please contact our Data Protection Lead before or after your appointment.2.  What We Record and WhyDuring your consultation, your clinician may activate an audio recording on our secure, encrypted clinical system. That recording is:processed in real time by our AI system to generate structured clinical notes; reviewed and verified by your clinician, who is responsible for the accuracy of your medical record;Original recordings may or may not be retained as part of your record in accordanceNo recording is made outside of formal clinical consultations. Waiting areas, corridors etc.3.  Our Legal Basis for Recording and Processing Your DataYour fertility health information is classified as special category data under the UK General Data Protection Regulation (UK GDPR). We are required by law to identify both a lawful basis for processing your personal data and a separate condition for processing special category data. We rely on the following:Lawful Basis (UK GDPR, Article 6):  Processing is necessary for the performance of clinical care (Art. 6(1)(b)) and, where applicable, in our legitimate interests in providing accurate and safe medical records (Art. 6(1)(f)).Special Category Condition (UK GDPR, Article 9(2)(h)):  Processing is necessary for the provision of health or social care treatment or the management of health-care systems. This is supported in UK domestic law by Schedule 1, paragraph 2 of the Data Protection Act 2018.This means that, in the context of direct patient care, we do not require your separate consent to process audio recordings as part of your clinical record. Obtaining such consent is already implied in your agreement to receive treatment. This is consistent with ICO guidance that in healthcare settings 'consent is often not the appropriate lawful basis under the GDPR' and that Article 9(2)(h) 'specifically legitimises processing for health or social care purposes.'However, because we value your autonomy and your right to be fully informed, we give you advance notice here, and your clinician will also inform you at the start of each recorded consultation.InstrumentRelevance to P4 ClinicUK GDPR Art. 6(1)(b) / (e)Lawful basis: processing necessary for performance of clinical care and in the legitimate interests of providing medically accurate recordsUK GDPR Art. 9(2)(h)Special category condition: processing health data necessary for provision of health or social care treatmentData Protection Act 2018, Sch. 1, Para. 2Domestic UK condition enabling Art. 9(2)(h): health or social care purposes, subject to professional secrecy obligationsHuman Fertilisation & Embryology Act 1990 (as amended)HFEA Code of Practice (9th Ed.) — clinics must maintain accurate, retrievable patient records; duty of accurate documentation supports audio-assisted note-takingNHS/Private Records Guidance (DPSST)Minimum 25-year retention of fertility records; audio recordings form part of clinical records and are subject to same retention and security obligationsInvestigatory Powers Act 2016 / RIPA 2000One-party consent rule: P4 Clinic as a party to the consultation may lawfully record; disclosure to third parties remains governed by UK GDPRICO Enforcement (2024)ICO issued enforcement notices to organisations deploying AI audio analysis without adequate patient disclosure — P4's transparency notice addresses this risk directly4.  How Your Recording Is ProtectedP4 Clinic's AI-enabled patient record system is an in-house, purpose-built platform designed and operated exclusively for clinical use within P4 Clinic. It is not a consumer or commercial third-party application. The system incorporates industry-standard security measures including:Encryption: End-to-end encryption of all audio data in transit and at rest (AES-256 or equivalent);Access control: Access controls with role-based permissions, ensuring only authorised clinical and administrative staff can access recordings linked to your records;Audit trails: Audit logging of all access to your patient record, including any access to or export of audio recordings;Minimisation: Data minimisation: audio recordings are processed to generate clinical notes and are not retained in raw audio form beyond the period necessary for clinical note verification by your clinician (typically [INSERT PERIOD]);Infrastructure: Physical and network security in line with NHS Digital Data Security and Protection Toolkit (DSPT) standards, to which P4 Clinic adheres;Testing: Penetration testing and vulnerability assessments conducted [annually / bi-annually] by independent third-party security specialists;Staff obligations: All staff with access to the system are subject to confidentiality obligations, data protection training, and professional regulatory duties under the relevant health professional codes (GMC, NMC, as applicable).5.  Who Has Access to Your Recordings and NotesYour audio recording and the AI-generated clinical notes derived from it are treated in the same manner as all other components of your medical record at P4 Clinic. Access is restricted to:Your treating clinician(s) and members of the direct clinical care team at P4 Clinic;Authorised administrative staff for the purposes of appointment management, billing, and medical records;The Human Fertilisation and Embryology Authority (HFEA), where required by our licence conditions and the Human Fertilisation and Embryology Act 1990 (as amended);Other healthcare providers involved in your care, where you have provided consent or where disclosure is necessary in the interests of your safety;Competent authorities where we are required by law to disclose (e.g. court order, CQC inspection).We do not sell, license, share with commercial third parties, or use your data for the training of external AI systems. Our in-house AI system operates only on our controlled infrastructure.6.  How Long We Keep Your DataAs a fertility clinic, we are required under HFEA licence conditions and NHS guidance to retain patient records for a minimum of 25 years (or until the patient reaches 50 years of age, whichever is longer). Audio recordings form part of your clinical record and are subject to the same retention schedule.Where raw audio recordings have been fully verified and incorporated into your clinical notes, we will delete the raw audio after notes unless retention is required for a specific clinical, regulatory, or legal purpose. Verified clinical notes are retained for the full statutory period.7.  Your RightsUnder the UK GDPR, you have the following rights in relation to your data. Note that some rights are qualified in the healthcare context by professional and statutory obligations:Right of access — you may request a copy of your patient records, including any retained audio recordings, under a Subject Access Request (SAR).Right to rectification — if you believe information derived from your consultation is inaccurate, you may ask your clinician to review and correct the record.Right to object — you may inform your clinician before a consultation that you do not wish it to be audio recorded. In that case, your clinician will take written notes in the conventional manner. This will not affect the treatment you receive.Right to erasure — this right is qualified in the healthcare context. We may be unable to erase records where retention is required under the HFEA Act, our licence conditions, or other applicable law.Right to data portability — where technically feasible, you may request your records in a structured, machine-readable format.To exercise any of these rights, please contact our Data Protection Lead (details in Section 9).8.  Opting Out of Audio RecordingYou have the right to decline audio recording.Please tell your clinician before your consultation begins if you do not wish the session to be audio recorded. Your clinician will take written notes instead. This will not in any way affect the quality of your care, your access to treatment, or any aspect of your relationship with P4 Clinic. Your decision will be recorded and respected.9.  Contact & ComplaintsP4 Clinic is registered as a Data Controller with the Information Commissioner's Office (ICO). Our ICO registration number is [INSERT NUMBER].Data Protection Lead:  Operational Manager P4 fertility. Email: secretary@p4fertility.co.ukIf you have a concern about how we handle your data that we are unable to resolve to your satisfaction, you have the right to lodge a complaint with the ICO at www.ico.org.uk or by calling 0303 123 1113.HFEA-regulated treatment patients may also raise data-related concerns with the Human Fertilisation and Embryology Authority at www.hfea.gov.uk.

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