Affiliate Disclosure: PharmaMate is an independent comparison service for pharmacy treatment consultations. We may earn a commission when you visit a pharmacy through links on our site. This does not affect the prices you pay. Our information is provided for reference purposes and does not constitute medical advice. All medications listed are prescription-only and require a consultation with a qualified healthcare professional.
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Data Protection Impact Assessment

Data Protection Impact Assessment (DPIA)

Organisation: PharmaMate Limited
Website: https://PharmaMate.co.uk
Date of assessment: 17 March 2026

1. Project Description

PharmaMate is an independent United Kingdom pharmacy price comparison website for GLP-1 medications, including Mounjaro, Wegovy, and Ozempic. The platform enables consumers to compare prices, delivery options, and service features across GPhC-registered online pharmacies.

PharmaMate is not a pharmacy and is not registered with the General Pharmaceutical Council (GPhC). We do not sell, supply, prescribe, or dispense any medicines. Revenue is generated through affiliate commissions when users visit pharmacy websites via links on our platform.

2. Data Processing Activities

2.1 Medication Request Forms

Field Detail
Data collected First name, email address (AES-256-CBC encrypted at rest), medication interest
Special category data Yes — medication interest constitutes health data under UK GDPR Article 9
Storage WordPress posts in the site database
Retention Automatically deleted after 12 months via scheduled cron
Legal basis Explicit consent (Article 6(1)(a) and Article 9(2)(a)) — obtained via consent checkbox on the form

2.2 Success Story Submissions

Field Detail
Data collected Name, email address (AES-256-CBC encrypted at rest), before/after photographs (EXIF metadata stripped on upload), story text
Special category data Yes — health-related narratives and photographs
Consent mechanisms Explicit health data consent checkbox and separate photo publication consent checkbox
Storage Custom database table
Legal basis Explicit consent (Article 6(1)(a) and Article 9(2)(a))

2.3 Affiliate Click Tracking (Aggregate)

Field Detail
Data collected Daily aggregate counters per link type, provider, medication, and page
Personal data No — no personally identifiable information is recorded
Legal basis Legitimate interest (Article 6(1)(f)) — business analytics and commission verification

2.4 Affiliate Redirect Tracking

Field Detail
Data collected Session hash (SHA-256 of IP address + User-Agent string), timestamp, provider, discount code used
Personal data Pseudonymised — raw IP address is not stored
Condition Only collected when the user has given tracking consent via cookie banner
Retention Automatically deleted after 90 days via scheduled cron
Legal basis Consent (Article 6(1)(a))

2.5 Cookie Consent Preferences

Field Detail
Data collected Consent choices across categories: essential, functional, analytics, health-related tracking
Storage Browser localStorage (client-side only)
Legal basis Essential for compliance with PECR and UK GDPR — no separate consent required

2.6 Newsletter Subscriptions

Field Detail
Data collected First name, email address, medication interests (health data)
Special category data Yes — medication interests
Processor MailerLite (Data Processing Agreement in place)
Legal basis Explicit consent (Article 6(1)(a) and Article 9(2)(a)) — obtained via health data consent checkbox

3. Special Category Data Assessment

Medication interests (e.g. selecting “Mounjaro” or “Wegovy”) constitute health data under UK GDPR Article 9. This applies to:

Safeguards: Explicit consent is obtained via clearly labelled checkboxes before any health data is collected. The cookie consent banner includes a separate “Health-Related Tracking” category that is off by default and requires affirmative opt-in.

4. Necessity and Proportionality

Processing Activity Why It Is Necessary
Medication request forms Enables users to express interest in specific treatments and receive tailored pharmacy comparisons. Without medication interest data, the service cannot provide relevant recommendations.
Success story submissions User-generated content that helps prospective patients make informed decisions. Health narratives and photos are voluntarily submitted and published only with explicit consent.
Aggregate affiliate tracking Required for business operation — verifying affiliate commissions and understanding which pharmacy services are most useful to users. Contains no personal data.
Redirect tracking Enables fraud detection and commission dispute resolution with pharmacy partners. Uses pseudonymised session hashes rather than raw identifiers. Only active with consent.
Cookie consent preferences Legal requirement under PECR to record and respect user cookie choices.
Newsletter subscriptions Enables users to receive updates about pharmacy pricing and availability for medications they are interested in. Medication interest is necessary to send relevant rather than generic communications.

5. Risk Assessment

Risk 1: Unauthorised access to encrypted email addresses

Likelihood Low
Severity Medium
Mitigation Email addresses are encrypted using AES-256-CBC with the WordPress authentication salt as the encryption key. Database access requires server-level credentials. WordPress admin access is restricted and protected by strong passwords.
Residual risk Low

Risk 2: Health data inference from browsing behaviour

Likelihood Medium
Severity Medium
Mitigation Default tracking is aggregate-only with no personal identifiers. Health-related tracking (which could link browsing to a pseudonymous session) requires explicit opt-in via a dedicated cookie consent category. Aggregate counters cannot be traced to individuals.
Residual risk Low

Risk 3: Misuse of success story photographs

Likelihood Low
Severity High
Mitigation EXIF metadata (including GPS coordinates) is stripped from all uploaded photographs. Explicit photo publication consent is required via a separate checkbox. Users may request removal of their story and photos at any time by contacting hello@pharmamate.co.uk. Stories are moderated before publication.
Residual risk Low

Risk 4: Data processor breach (MailerLite, hosting provider)

Likelihood Low
Severity High
Mitigation Data Processing Agreements (DPAs) are in place with all processors. MailerLite operates under Standard Contractual Clauses for international transfers. Hosting provider access is restricted to necessary operational personnel. Processor security practices are reviewed annually.
Residual risk Low–Medium

Risk 5: Stale personal data retained beyond necessity

Likelihood Low
Severity Low
Mitigation Automated WordPress cron jobs delete medication request form submissions after 12 months and affiliate redirect tracking records after 90 days. Newsletter unsubscribes are processed within 30 days by MailerLite. Retention schedules are documented in the Privacy Policy.
Residual risk Low

6. Measures to Reduce Risk

7. Decision

Based on this assessment, the identified data processing activities may proceed with the safeguards described above. The residual risks are acceptable given the measures in place. This DPIA should be reviewed annually or when significant changes are made to data processing activities.

8. Sign-Off

Role Name Date Signature
Data Protection Officer / Reviewer ____________________ ____________________ ____________________
Project Owner ____________________ ____________________ ____________________

Last updated: 17 March 2026

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