1. PRIVACY POLICY

This Privacy Policy explains how Clarity Postmortem Imaging Limited (“we”, “us”, “our”) collects, uses, discloses and protects personal data when you use our website claritypmct.co.uk, contact us, or when we provide post -mortem CT (PMCT) services to coroners, NHS bodies, funeral directors, law -enforcement teams, legal representatives, and bereaved families. We comply with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

Company Details: Clarity Postmortem Imaging Limited (Company No: 16906094),

Registered Office: Burleigh Medical Centre, Burleigh Street, Barnsley, United Kingdom, S70 1DR.

Privacy contact: info@claritypmct.co.uk.

1.1 Our GDPR Role

For coronial and NHS -commissioned post -mortem CT services, we act primarily as a Data Processor. For private PMCT instructions, general website communications, and business administration, we act as a Data Controller.

1.2 What data we collect

(A) Website/enquiries – names, email, phone, and technical data (IP address, device information, cookies/analytics if consented).

(B) Service provision (PMCT) – case identifiers, scan metadata, images and reports; contact details for next of kin and professionals; information shared by authorised representatives.

(C) Operations – supplier/partner contacts, billing and compliance records.

1.3 Where we get data

Directly from you; from coroners’ services, NHS Trusts, GPs, funeral directors, police and legal representatives as part of death -investigation pathways.

1.4 Data about deceased persons

UK GDPR does not apply to data relating to deceased individuals. However, we treat all PMCT data with strict confidentiality and apply equivalent security and ethical safeguards.

1.5 Purposes and lawful bases

Website/communications – legitimate interests (responding, security), and analytics with consent under PECR.

PMCT case work – public task (assisting coroners/NHS), legal obligation, contract (private requests), or legitimate interests (limited private administration).

Where data about living individuals includes special category data, we rely on Article 9 conditions such as substantial public interest (supported by a Schedule 1 policy document), health/diagnosis, or legal claims, as appropriate.

1.6 Law enforcement and legal requests

Where we receive requests from police or law enforcement under appropriate lawful authority, we process personal data under the legal bases of legal obligation or substantial public interest (Schedule 1, Data Protection Act 2018).

1.7 Use of PMCT data

Acquire PMCT images, perform reconstructions, produce reports; maintain chain -of -custody, audit logs and secure storage suitable for medico -legal evidence; disclose to the commissioning authority and authorised recipients as required.

1.8 Sharing

We share data with coroners/coroners’ officers, pathologists, courts/tribunals, law -enforcement, NHS Trusts/GPs, funeral directors, and authorised legal representatives; with service providers (processors) under Article 28 contracts; and with professional advisers. We do not sell personal data.

1.9 International transfers

PMCT reports and images may be stored or accessed in the USA or EU. We use appropriate transfer tools (e.g., UK International Data Transfer Agreement or Addendum, or adequacy regulations) plus supplementary safeguards where required. Details available on request.

1.10 Retention

Website enquiries: 12-24 months after last contact. Administrative case files: approximately 7 years. PMCT imaging and reports: 7-15 years (or as required by coronial/NHS evidential needs).

These retention periods reflect evidential requirements for coronial investigations, statutory inquiries, defence of legal claims, and NHS/clinical governance.

1.11 Your rights (for living individuals)

You have rights to access, rectification, erasure, restriction, objection, and portability (where applicable). Some rights may be limited in the administration of justice or coronial contexts. Contact info@claritypmct.co.uk. We do not use automated decision-making or profiling in the provision of our services

1.12 Security

We implement technical and organisational measures including encryption, role -based access control and MFA, audit logs, staff training, vulnerability management and incident response. We will notify the ICO and affected individuals where legally required in the event of a personal -data breach.

Emails and telephone calls are not end -to -end encrypted. Please avoid sending unnecessary sensitive information unless required.

If you suspect a security vulnerability on our site or systems, please report it immediately to info@claritypmct.co.uk.

1.13 Cookies and analytics

We use essential cookies and, with consent, optional analytics; see our Cookies Policy below. We do not use manipulative designs (“dark patterns”) to influence cookie choices. You can withdraw your consent at any time via cookie settings.

Updates: we may update this policy and will post the latest version with a new “Last updated” date. Complaints: you may complain to the UK ICO (ico.org.uk).

2. TERMS & CONDITIONS

These Terms & Conditions (the “Terms”) apply to your use of the website claritypmct.co.uk (the “Site”) and to any enquiries you make to Clarity Postmortem Imaging Limited. If you do not agree with these Terms, please do not use the Site.

Who we are: Clarity Postmortem Imaging Limited (company number 16906094) with registered office at Burleigh Medical Centre, Burleigh Street, Barnsley, United Kingdom, S70 1DR. Contact: info@claritypmct.co.uk.

About our Site and Services: The Site provides general information about our Services. Content on this Site is for information only and does not constitute medical or legal advice. We provide Services to commissioning authorities (e.g., coroners and NHS Trusts), to other professional clients and, in limited cases, to private clients under separate written agreements.

2.1 Acceptable use

Do not misuse the Site (e.g., unauthorised access, malware, scraping). Do not rely on Site content as a substitute for professional advice or for urgent decision -making.

You must not use automated tools (including AI agents, scraping bots, or model -training tools) to extract, copy, index, or reuse any images, text, reports, or other content from the Site.

2.2 Accounts and submissions

Keep credentials secure; provide accurate information. You grant us a licence to use information you submit solely to respond to your enquiry and to operate the Site in accordance with our Privacy and Cookies Policies.

2.3 Service availability

We do not guarantee continuous availability of the Site. Access may be temporarily suspended for maintenance, security updates, system failures, or events outside our reasonable control.

2.4 Intellectual property

All content on the Site (text, graphics, logos, images) is owned by or licensed to us. You may view, download and print content for personal or internal business purposes; other uses require our prior written consent.

2.5 Third -party links

We are not responsible for third -party websites or resources.

2.6 Disclaimers and liability

The Site is provided “as is” and “as available”, without warranties of any kind to the maximum extent permitted by law. PMCT has benefits and limitations; outcomes are case -specific.

Nothing in these Terms limits or excludes liability that cannot be limited or excluded by law (including death or personal injury due to negligence, or fraud). Subject to that, we exclude all implied warranties and conditions and will not be liable for loss of profits, revenue, business, goodwill or data; indirect or consequential loss; losses caused by third -party information or instructions; or use of the Site contrary to these Terms. For business -to -business use, any remaining liability is limited to £10,000 in aggregate.

2.7 Indemnity (business users)

If you use the Site for business purposes, you will indemnify us for reasonable losses arising from unlawful use or breach of these Terms. This indemnity does not apply to private individuals using the Site in a non -business capacity.

2.8 Limitation on medical/expert advice

PMCT reports are interpretative and must be used only within the scope defined by the commissioning authority. They do not replace formal post -mortem examination unless authorised by the coroner.

2.9 Contact hours and urgent instructions

We aim to respond to enquiries within one working day. Our standard administrative hours are Monday-Friday, excluding UK public holidays. If your request relates to an urgent coroner’s instruction, please use the contact method provided by the coroner’s office. The website contact form is not monitored 24/7.

2.10 Changes, governing law and jurisdiction

We may update these Terms or the Site at any time. These Terms (including non -contractual disputes/claims) are governed by the laws of England and Wales; the courts of England and Wales have exclusive jurisdiction.

3. DISCLAIMER

Information on this website is provided for general information only. It is not medical advice, legal advice, expert testimony, or a substitute for professional judgement. Do not rely on it for case management, clinical decision -making or litigation strategy.

PMCT limitations: PMCT cannot reliably detect all causes of death, including certain natural diseases, microscopic pathology, toxicology -related findings or early inflammatory processes. Its suitability depends on case circumstances and commissioning authority directions. While PMCT may in some cases reduce the need for invasive autopsy, outcomes are case -specific and cannot be guaranteed.

Reasonable skill and care: All PMCT reports are produced with reasonable skill and care, but no imaging technique can guarantee exhaustive findings. Final determination of cause of death rests with the coroner or relevant authority.

External links: links to third -party sites are provided for convenience only. We have no control over, and accept no responsibility for, the content or practices of any third -party site.

Liability: nothing in this Disclaimer excludes or limits liability that cannot be excluded or limited by law. Subject to that, we exclude liability for any loss or damage arising from your use of (or reliance on) the Site, its content or any linked site, including loss of profits, business or data, and indirect or consequential loss.

Contact: info@claritypmct.co.uk.

4. COOKIES POLICY

This Cookies Policy explains how we use cookies and similar technologies on claritypmct.co.uk. Under UK law, you must be told if cookies are used and, for non -essential cookies, you must be given a genuine choice to consent or reject. Strictly necessary cookies do not require consent.

What are cookies? Cookies are small files placed on your device when you visit a website. Similar technologies include local storage, tracking pixels and device fingerprinting.

How we use cookies: Strictly necessary (essential for security and to provide the service you request); Analytics (optional – helps us understand how the site is used and improve performance); Functionality (optional – remembers preferences to enhance user experience). We do not deploy optional cookies unless you give consent via our cookie banner or settings.

Managing your choices: on your first visit, you will see a banner asking you to Accept or Reject optional cookies, with a link to Manage preferences. You can change your choice at any time via the “Cookies” link in our footer. You can withdraw your consent to optional cookies at any time by changing your preferences. We do not use manipulative designs (“dark patterns”) to influence cookie choices.

International transfers: if optional analytics or functionality providers host data outside the UK (for example, in the USA), we will implement appropriate safeguards (such as the UK International Data Transfer Agreement or Addendum) and conduct transfer risk assessments where required.

Retention: cookie lifespans vary. We set strictly necessary cookies for up to 12 months, and optional cookies only after consent. Updates: we may update this policy and will post the latest version here. Contact: info@claritypmct.co.uk.

4.1 Cookie banner wording

We use essential cookies to make this site work. With your permission, we’d also like to use optional analytics cookies to help us improve it. You can accept, reject, or set your preferences. We won’t set optional cookies unless you enable them. [Accept all] [Reject all] [Manage settings]

5. DATA PROCESSING AGREEMENT (Controller-Processor) – TEMPLATE

Parties: Controller – [Coroner’s Service / NHS Trust / Funeral Director / Other commissioning authority] (“Controller”); Processor – Clarity Postmortem Imaging Limited, company number 16906094, Burleigh Medical Centre, Burleigh Street, Barnsley, United Kingdom, S70 1DR (“Processor”).

1. Background: This Agreement sets out the terms on which the Processor will process personal data on behalf of the Controller in connection with post -mortem CT (PMCT) and related services (the “Services”).
2. Roles and scope: The Controllerdeterminesthe purposes and means of processing; the Processor shall only process personal data on documented instructions of the Controller, including with regard to any international transfers, unless required to do so by UK law.
3. Duration: This Agreementremainsin force for the duration of the Services and until deletion/return of personal data in accordance with Clause 12.
4. Processor obligations (Article 28 UK GDPR): (a) Confidentiality; (b) Security measures; (c) Sub -processors only with priorauthorisationand under equivalent obligations; (d) Assist with data subject rights; (e) Assist with security, breach notification, DPIAs and prior consultation; (f) Maintain records and allow reasonable audits; (g) Delete/return data at end of Services unless UK law requires storage. We maintain an appropriate policy document for Schedule 1 special category conditions under the Data Protection Act 2018.
5. International transfers: Personal data may be transferred to or accessed from countries outside the UK only with the Controller’s documented instructions and subject toappropriate safeguards(e.g., the UK International Data Transfer Agreement or Addendum, or adequacy regulations) and a Transfer Risk Assessment where applicable.
6. Chain of custody and evidential integrity: For PMCT imaging and related data, the Processor willmaintainchain -of -custody logs, audit trails, and access controls proportionate to evidential needs and will cooperate to provide statements or evidence where required.
7. Retention: The Controllerdeterminesretention. Where applicable to coronial matters, imaging and reports are typically retained for 7-15 years or as the Controller directs. The Processor shall not retain personal data longer than required.
8. Personal data breaches: Notify the Controller without undue delay and provide necessary information.
9. Sub-processors: On request, we will provide a list of all current sub-processors and notify the Controller in advance of any intended changes, allowing the Controller to object on reasonable grounds.
10. Prohibition on secondary use: We will not use PMCT images, reconstructions or associated data for training, research or teaching unless expresslyauthorisedin writing by the Controller and subject to ethical safeguards.
11. Liability: Governed by the main Services agreement; nothing limits liability contrary to law.
12. Deletion/return: On the Controller’s instruction,deleteor return all personal data at the end of the Services unless UK law requires storage.
13. Governing law and jurisdiction: England and Wales; exclusive jurisdiction of its courts.

 

Schedule A – Processing Summary

Subject -matter and duration: PMCT imaging, reconstruction and reporting for the duration of the commission plus retention as directed by Controller.

Nature and purpose: Acquisition, storage, review and reporting of post -mortem imaging; disclosure to authorised recipients in coronial/clinical/legal pathways.

Categories of data subjects: Living individuals whose data may be processed (e.g., next of kin, professionals, witnesses). Data about deceased persons may be handled with confidentiality but is generally outside UK GDPR unless it identifies living persons.

Types of personal data: Identifiers (names, contact details), role details, communications, and limited special category data about living persons where necessary.

Schedule B – Security Measures

Encryption in transit and at rest (where supported), role -based access controls, MFA for remote access;

Secure PACS/VNA with audit logging and tamper -evident storage where feasible;

Least -privilege access, joiner/mover/leaver controls, staff training and confidentiality;

Network segregation, vulnerability management and patching;

Incident response and business continuity procedures.

Schedule C – Authorised Sub -processors

Available upon request and detailed in specific client schedules.

Schedule D – International Transfer Safeguards

Available upon request and detailed in specific client schedules.

6. ACCESSIBILITY STATEMENT

We are committed to making our website accessible and usable by as many people as possible. We aim to meet WCAG 2.2 AA standards and continuously improve accessibility.

What we do: design for keyboard access, visible focus, sufficient colour contrast, meaningful link text, alternative text for images, and predictable navigation; test with assistive technologies where feasible; ensure mobile and tablet accessibility.

Non -accessible content: some legacy documents or third -party widgets may not fully meet WCAG 2.2 AA. We are working to fix these issues or provide accessible alternatives.

Feedback and contact: if you need information in a different format (accessible PDF, large print, easy read) or encounter accessibility problems, email info@claritypmct.co.uk. We will respond within 10 working days.

Enforcement: if you are unhappy with our response, you can contact the UK Equality Advisory and Support Service (EASS) for advice.

7. DIRECTOR, SHAREHOLDER & PERSONNEL PROTECTION

To maximise protection for all directors, shareholders, officers, employees, consultants and authorised contractors of Clarity Postmortem Imaging Limited (the “Clarity Personnel”), the following provisions apply across all Terms & Conditions, Privacy Policies, Disclaimers and Agreements:

1. Extended Protection: All limitations of liability, exclusions, warranties, indemnities and disclaimers contained in this document apply equally to Clarity Postmortem Imaging Limited and to each individual member of the Clarity Personnel.
2. No Personal Duty of Care: No individual director, officer, employee, radiologist, consultant or contractor assumes a personal duty of care to any website user, client, commissioning body, third party, or any other individual or organisation. All duties are owed solely by Clarity Postmortem Imaging Limited, except where such exclusion is not permitted by law.
3. Third-Party Rights (CRTPA 1999): The protections, exclusions, limitations and indemnities in this document may be enforced directly by the Clarity Personnel under the Contracts (Rights of Third Parties) Act 1999. The parties may vary or terminate this document without the consent of any Clarity Personnel.
4. Indemnity Extension: Business users agree to indemnify and hold harmless Clarity Postmortem Imaging Limited and all Clarity Personnel from reasonable losses, costs, liabilities or expenses arising from misuse of the Site, Services, PMCT imaging, reports, or breach of these Terms. This indemnity does not apply to private individuals using the Site in a non -business capacity.
5. Time Limitation for Claims: Any claim against Clarity Postmortem Imaging Limited or Clarity Personnel must be brought within 12 months from the date of the event giving rise to the claim or delivery of the relevant PMCT report, whichever is earlier. Claims brought after this period are barred.
6. Limitation of Liability Cap: Unless prohibited by law, the total liability of Clarity Postmortem Imaging Limited and Clarity Personnel is limited to the lower of: (a) the total fees paid in the previous 12 months for commissioned services; or (b) £10,000 for general website use or non -contracted interactions.
7. Insurance:For the avoidance of doubt, the applicability of all liability protections, exclusions and limitations set out in this document is in no way contingent upon, nor shall it be construed as being materially influenced by, the existence, availability, continuity or scope of any insurance arrangement, whether presently in force, previously maintained, intermittently held, required under a commissioning framework, or arising under any contractual or statutory instrument. Clarity Postmortem Imaging Limited may, where appropriate, necessary, mandated, permitted, or otherwise determined in its sole discretion, elect to procure, maintain, vary, discontinue, or refrain from obtaining professional indemnity or Directors’ & Officers’ (D&O) insurance, and no inference as to the presence or absence of such cover shall be drawn from these Terms or any related communication. No individual member of the Clarity Personnel shall assume, or be deemed to have assumed, any personal liability except where such exclusion is expressly prohibited by law.

8. Personal Liability Exclusion: Except where the law does not permit exclusion, Clarity Personnel shall not be personally liable for any loss, damage, cost, claim or liability arising from use of the Site, PMCT imaging, communications, reports, or interactions with Clarity Postmortem Imaging Limited.

While we are not legally required to appoint a formal Data Protection Officer, our Privacy Manager oversees compliance and can be reached at info@claritypmct.co.uk