Compliance & Governance Statement

Renominate is a structured communication service provided to UK community pharmacies by DHM Digital Limited (Company No. 16953956).

This page outlines our regulatory position, data protection framework, and governance controls.

1. Scope of Service

Renominate provides structured, non-clinical communication support to community pharmacies in relation to:

  • Clarification of unexplained EPS nomination changes

  • Patient communication regarding nomination status

  • Patient engagement and retention communications

Renominate:

  • Does not provide clinical advice

  • Does not access NHS clinical systems

  • Does not alter EPS nominations

  • Does not provide dispensing services

  • Does not provide medical or pharmaceutical guidance

All clinical responsibility remains with the contracted pharmacy.

2. Regulatory Position

Renominate operates as a commercial service provider to community pharmacies.

We are not:

  • An NHS contractor

  • A clinical provider

  • A distance-selling pharmacy

  • A dispensing entity

We act solely as an authorised communication agent of the pharmacy under written agreement.

3. Data Protection Framework

Renominate operates in accordance with:

  • UK GDPR

  • Data Protection Act 2018

  • Applicable PECR provisions

For all pharmacy partnerships:

  • The pharmacy is the Data Controller

  • Renominate acts as a Data Processor

  • A signed Data Processing Agreement (DPA) is in place

  • Processing is limited to defined contractual purposes

We do not determine independent purposes for patient data.

4. Lawful Basis

The lawful basis for any patient communication is determined by the pharmacy as Data Controller.

Where applicable, pharmacies may rely on:

  • Legitimate Interest (Article 6(1)(f))

  • Healthcare administration purposes

Renominate provides a structured Legitimate Interest Assessment (LIA) framework to support pharmacy documentation where required.

All communications are:

  • Limited in frequency

  • Transparent in purpose

  • Respectful of patient choice

5. Patient Communication Controls

Our communication protocol is designed to ensure:

  • Neutral and factual messaging

  • No inducement or incentives

  • No pressure or persuasion

  • Clear explanation of nomination status

Where nomination changes occur:

  • Written confirmation is issued

  • Audit records are maintained

  • Patients who decline to re-nominate receive written confirmation of their decision

This ensures a documented and transparent audit trail.

6. Information Governance Safeguards

Renominate implements appropriate technical and organisational measures including:

 

 

  • Controlled data access

  • Defined data minimisation practices

  • Secure handling procedures

  • Documented retention policies

  • Confidentiality agreements

We process only the minimum data required to fulfil the agreed service scope.

7. Clinical Boundaries

Renominate personnel:

  • Do not provide medical advice

  • Do not interpret prescriptions

  • Do not provide pharmaceutical guidance

  • Do not discuss clinical treatment plans

Any clinical queries are referred directly back to the pharmacy.

8. Governance Documentation

Each pharmacy engagement includes:

  • Terms of Service

  • Data Processing Agreement

  • Confidentiality provisions

  • Defined scope of activity

  • Defined communication boundaries

Copies of governing documents are available upon request.

9. Transparency & Engagement

We welcome dialogue with:

  • NHS England

  • Integrated Care Boards

  • Local Pharmaceutical Committees

  • Trade associations

  • Governance and compliance bodies

 

For compliance enquiries, please contact:

Email

support@renominate.co.uk

 

Address

Renominate

Moorgate Crofts Business Centre,

South Grove, Moorgate, Rotherham S60 2DH

 

Renominate is a trading service of DHM Digital Limited.

Registered in England & Wales No. 16953956.