UK: Summary of the different type of campaigns you may choose to send, explaining the differenes and sharing examples
Legitimate Interest Campaigns
For a pharmacy within the UK, legitimate interests under the GDPR can cover a range of activities where the pharmacy has a valid business or operational need to process personal data - please refer to Article 6 (1) (f) for reference. However, it is essential that these interests are balanced against the rights and freedoms of the individuals whose data is being processed. Below are several examples of legitimate interests that a UK pharmacy may rely on for processing patient data.
Therefore, a UK pharmacy can run an opt-out campaign to communicate about medications and health, provided the communications are non-marketing and are based on legitimate interests or contractual necessity. However, marketing communications would require explicit opt-in consent instead. It’s important to ensure that the opt-out process is simple, transparent, and respects patient preferences e.g. Opt-out campaigns need to be clear that these are healthcare-related communications and include a link “Reply STOP to opt-out.”
Legitimate Interest Campaign Examples:
1. Providing Healthcare Services- Prescription Reminders: Contacting patients to remind them to pick up prescriptions or take medications.
- Medication Review Services: Offering patients medication reviews or advising them on safe usage, possible interactions and potential side effects.
- Adherence Support: Sending reminders or follow-up communications to encourage patients to adhere to prescribed medication regimens.
- Vaccination Services: Contacting patients about vaccinations they are eligible for, such as flu or shingles vaccines, based on their medical history.
- Health Consultations: Contacting patients to offer healthcare consultations or professional
- services (e.g., blood pressure checks, diabetes monitoring, smoking cessation programs).
- Emergency Notifications: Reaching out to patients in cases where there may be a recall or alert related to the medication they are using, or if there is a change in their prescribed treatment.
- Drug Safety and Recall: Notifying patients about drug recalls, adverse drug reactions or any safety issues related to their medication.
- Medical Records Management: Keeping accurate records of prescriptions, medical history or other health-related data, in line with providing appropriate care and complying with regulations.
- Monitoring and Preventing Fraud: Using personal data to detect and prevent fraudulent prescriptions, misuse of services or identity theft.
- Staff Training: Using anonymised or pseudonymised patient data to train staff and improve service delivery in the pharmacy.
- Internal Audits and Reporting: Using personal data for auditing, compliance, and reporting purposes, to ensure that the pharmacy operates in accordance with legal and regulatory
- requirements.
- Data Analytics for Service Improvement: Analysing data to improve pharmacy services, such as enhancing medication dispensing processes, improving customer service or evaluating patient health trends.
- Health-Related Marketing (Non-Promotional): Contacting patients about public health programs/services or professional services they may be eligible for (e.g., health screenings, vaccination campaigns, medication reviews) based on their medical history.
- Educational Communications: Sending patients health information related to their conditions, such as managing chronic conditions, dietary advice or exercise recommendations.
- Regulatory Reporting: Complying with pharmacy regulations or the Care Quality Commission
- (CQC) in the UK, where patient data is required to be processed for safety, quality control or reporting purposes.
- Record-Keeping for Tax or Financial Reporting: Using personal data for financial record-keeping, such as generating invoices for NHS prescriptions or payments.
- Insurance Purposes: Using personal data to process claims for insurance or liability coverage in cases where the pharmacy is liable for providing healthcare services.
- Risk Assessment: Using patient data to assess risk for insurance purposes, particularly in relation to health conditions or medication use.
Pharmacy Promotions Campaigns
For a pharmacy within the UK, pharmacy promotions refer to communications that involve marketing or advertising, such as special offers, discounts, loyalty programs, or product recommendations. Under GDPR, these activities require explicit opt-in consent from the recipient before sending promotional messages.
Pharmacy Promotions Campaigns Examples:
1. Seasonal Promotions- Discounted Health Products: Offering seasonal discounts on items like allergy relief, cold and flu medications, or sun care products.
- Holiday Specials: Promoting special offers during holidays such as Christmas, Easter, or Valentine’s Day, like gift sets or holiday-themed health kits.
- Points for Purchases: Encouraging patients to join a loyalty program where they can earn points on each purchase for future discounts.
- Exclusive Member Discounts: Providing special offers or discounts exclusive to loyalty program members.
- Introducing New Products: Informing customers about the arrival of new healthcare products, vitamins, or supplements.
- Special Introductory Offers: Offering discounts or incentives for trying newly launched products.
- Vaccination Promotions: Advertising flu shots, COVID-19 vaccinations, or travel vaccines with promotional offers.
- Health Check-Up Packages: Promoting discounted rates on health checks like cholesterol testing or diabetes screening.
- Newsletter Sign-Up Benefits: Offering exclusive discounts or early access to sales for newsletter subscribers.
- Auto-Refill Discounts: Providing discounts for patients who enrol in automatic medication refill services.
Enrolment Campaign Examples
SMS Examples
Health Outreach for Newly Dispensed Patients |
Hi {First Name}, At {Pharmacy Name}, we're here to support your health with important information, your prescription updates and tailored pharmacy services via SMS. Click [link] to set your preferences. |
Opt-In for Promotional Material |
Hi {First Name}, Get updates on pharmacy services, products & benefits from {Pharmacy Name} via SMS. Click [link] to set your preferences. |
Combined Health Outreach and Promotions |
Hi {First Name}, At {Pharmacy Name}, we're here to support your health with important information, your prescription updates plus relevant pharmacy services and products via SMS. Click [link] to set your preferences. |
Email Examples
Health Outreach for Newly Dispensed Patients |
Dear {First Name},
|
Opt-In for Promotional Material |
Dear {First Name},
|
Combined Health Outreach and Promotions |
Dear {First Name},
|