RENOMINATE – TERMS OF SERVICE

 

For Community Pharmacies Using the Renomination & Engagement Service

Last updated: 21st December 2025

Renominate is a specialist digital renomination and patient engagement service operated by DHM Digital Limited (Company Number 16953956).

These Terms of Service explain how Renominate operates, how pharmacy and patient data is handled, and the responsibilities of both parties when using the service.

By engaging Renominate, you (“the Pharmacy”, “you”, “your”) agree to these Terms.

1. About Renominate

Renominate is a pharmacy-specific service designed to help community pharmacies identify, recover, and retain patients whose EPS nominations have moved away due to system behaviour, inactivity, or default changes.

The service focuses on patient-led, informed renomination and continuity of care, not mass switching or marketing-driven patient acquisition.

Renominate does not provide clinical services, dispensing services, or medical advice. All clinical responsibility remains with the Pharmacy.

2. Ownership & Operation

Renominate is owned and operated by:

DHM Digital Limited

Company Number: 16953956

Registered in England and Wales

DHM Digital Limited is responsible for service delivery, data processing, security, and compliance.

3. Scope of the Service

Renominate supports pharmacies by:

Re-engaging eligible patients whose nominations have moved

Supporting informed, patient-initiated renomination

Providing structured communication workflows

Recording patient outcomes

Reporting renomination and engagement results back to the Pharmacy

Renominate does not:

Change EPS nominations directly

Access pharmacy PMR systems

Make clinical decisions

Contact patients outside authorised campaigns

4. Data Protection & Confidentiality

Data Protection, Agency and Processing

When providing the Renominate service:

The pharmacy (“Client”) acts as the Data Controller for all patient personal data at all times.

Renominate acts solely as the Data Processor and authorised agent, processing personal data only on the documented instructions of the Client and strictly for the purposes of delivering the Renominate service.

The Client confirms that:

It has carried out its own review of lost patient nominations, and

It will provide only records relating to patients where it is not aware that the patient knowingly authorised a nomination change.

Renominate shall:

Contact only those patients identified and authorised by the Client

Limit all patient contact to confirmation of nomination awareness

Use neutral, factual, and non-promotional communication

Cease processing immediately where a patient confirms the change was authorised

Renominate shall not:

Independently determine which patients are contacted

Market pharmacy services to patients

Interfere with legitimate patient choice

Process personal data for any purpose outside the agreed service scope

All data processing is governed by the applicable Data Processing Agreement, which forms part of these Terms.

Renominate recognises the sensitivity of pharmacy and patient data and applies healthcare-grade data protection standards at all times.

The service operates in compliance with:

UK GDPR

Data Protection Act 2018

ICO guidance

NHS data protection principles (where applicable)

The Pharmacy remains the Data Controller.

Renominate acts solely as a Data Processor, under the Pharmacy’s instruction.

5. Patient Data Use & Limitations

Only the minimum data required to deliver the service may be shared, typically:

Patient name

Postal address

Telephone number

Date the EPS nomination moved

No clinical records, prescription history, diagnoses, or NHS numbers are required or processed.

Patient data is used only to:

Deliver the renomination service

Record engagement outcomes

Report results back to the Pharmacy

Patient data is never used for marketing, resale, profiling, or third-party purposes.

6. Data Security Measures

Renominate applies appropriate technical and organisational safeguards, including:

Encrypted data transfer and storage

Restricted, role-based access

Secure systems and monitoring

No unnecessary duplication of data

Data minimisation at every stage

7. Data Retention & Deletion

Patient data is retained only for the duration required to deliver the service and reporting.

Upon completion and Pharmacy acceptance of outcomes:

Patient data is securely deleted

Backups are removed in line with deletion cycles

Written confirmation of deletion is provided

8. Pharmacy Responsibilities

The Pharmacy agrees to:

Provide accurate and lawfully obtained data

Confirm an appropriate lawful basis for patient contact

Ensure communications comply with NHS, ICO, and regulatory guidance

Maintain its own patient consent and record-keeping obligations

The Pharmacy remains responsible for:

Clinical decisions

Patient relationships

EPS nomination rules

Communications outside the Renominate service

9. Renominate Responsibilities

Renominate is responsible for:

Secure handling of all shared data

Delivering the service as described

GDPR-compliant processing

Reporting outcomes transparently

Acting only on Pharmacy instruction

Renominate does not provide clinical advice or access pharmacy systems.

10. Sub-Processors

Where infrastructure services are required (e.g. secure hosting or messaging platforms), Renominate uses GDPR-compliant sub-processors under strict contractual controls.

Sub-processors may only process data on Renominate’s behalf and for the agreed purpose.

11. Fees & Billing

Service fees, pricing models, and any performance-based arrangements are agreed separately at the point of engagement.

No fees are charged outside agreed terms.

12. Limitation of Liability

Renominate will take all reasonable steps to deliver the service securely and professionally but cannot be held liable for:

Errors caused by inaccurate data supplied by the Pharmacy

Regulatory consequences arising from Pharmacy misuse of data

External system failures beyond reasonable control

Liability is limited to fees paid in the preceding 4 weeks, except where limited by law.

13. Termination

Either party may terminate the service with written notice.

Upon termination:

Processing ceases

Data is deleted upon request

Access to reports ends

Confidentiality and data protection obligations survive termination.

14. Governing Law

These Terms are governed by the laws of England and Wales, with exclusive jurisdiction of the English courts.

15. Contact Information

Renominate

Operated by DHM Digital Limited

Company Number: 16953956