GDPR 2018 Privacy Notice
This document refers to personal data, which is defined as information concerning any living person (a natural person who hereafter will be called the Data Subject) that is not already in the public domain. The General Data Protection Regulation (GDPR) which is EU wide and far more extensive than its predecessor the Data Protection Act, along with the Privacy and Electronic Communications Regulations (PECR), seek to protect and enhance the rights of EU data subjects. These rights cover the safeguarding of personal data, protection against the unlawful processing of personal data and the unrestricted movement of personal data within the EU and its storage within the EEA.
1 – The Practice Apple Tree Osteopaths and our colleagues at Chiltern Breastfeeding Partnership which hereafter for the purposes of this Privacy Notice will be referred to as the Practice, is pleased to provide the following information:
2 – Personal Data
a) The Practice may require detailed medical information. We will only collect what is relevant and necessary for your treatment. When you visit our practice, we will make notes which may include details concerning your / your child’s medication, treatment and other issues affecting your health as well as photographs and/or videos and copies of letters and reports. This data is always held securely, is not shared with anyone not involved in your treatment, although for data storage and administrative purposes it may be handled by pre-vetted staff who have all signed an integrity and confidentiality agreement. To be able to process your personal data it is a condition of any of our treatment and advice that you give your explicit consent to allow The Practice to document and process your / your child’s personal medical data. Contact details provided by you such as telephone numbers, email addresses, postal addresses may be used to remind you of future appointments and provide reports, auditing or other information concerning your treatment.
b) The Practice may also use the contact details provided by you to respond to your enquiries, including making telephone contact, text message and emailing information to you which the practice believes may be of interest to you.
c) In making initial contact with the practice you consent to the Practice maintaining a marketing dialogue with you until you either opt out (which you can do at any time) or we decide to desist in promoting our services. The Practice may occasionally also act on behalf of its patients and clients in the capacity of data processor, when we may promote other specialists, who may not be employed by us. The Practice do not broker your data and you can ask to be removed from our relationship database by emailing the practice using the contact details provided at the end of this Privacy Notice.
d) Some basic personal data may be collected about you from the forms and surveys you complete, from records of our correspondence and phone calls and details of your visits to our website, including but not limited to, personally identifying information like Internet Protocol (IP) addresses.
f) The Practice will only collect the information needed so that we can provide you with the services you require, the business does not sell or broker your data.
g) The Practice collects data in order to process payment for services including managing payments and collecting / recovering money owed. For the purposes of account management, external accountants, who have a legal obligation to maintain your confidentiality, will have access to receipts, bank transactions and other accounting data.
3 – Legal basis for processing any personal data
To meet our contractual obligations obtained from explicit Patient Consent and legitimate interest to respond to enquiries concerning the services provided.
4 – Legitimate interests pursued by The Practice
To promote services provided by The Practice.
5 – Consent
Through agreeing to this privacy notice you are consenting to The Practice processing your personal data for the purposes outlined. You can withdraw consent at any time by using the email address provided at the end of this Privacy Notice.
6 – Disclosure
The Practice will endeavour to keep your personal information safe and secure. The Practice will not disclose your Personal Information unless compelled to, in order to meet legal obligations, regulations or valid governmental requests. The practice may also enforce its Terms and Conditions, including investigating potential violations of its Terms and Conditions to detect, prevent or mitigate fraud or security or technical issues; or to protect against imminent harm to the rights, property or safety of its staff.
7 – Retention Policy
The Practice will process personal data during the duration of any treatment and will continue to store only the personal data needed for eight years after the contract has expired to meet any legal obligations. After eight years all personal data will be deleted, unless basic information needs to be retained by the Practice to meet future obligations to you, such as erasure details. Records concerning minors will be retained until the child has reached the age of twenty-five.
8 – Data storage
Data is stored online on the confidential web-based software Cliniko and Cliniqapps which can also be accessed by the administrative team and associates of Apple Tree Osteopaths and Chiltern Breastfeeding Partnership. Data may be stored on password-protected computers and a secure online backup system. The Practice endeavours to ensure paper data is stored securely.
9 – Your rights as a data subject
At any point whilst The Practice are in possession of, or processing your personal data, all data subjects have the following rights:
- Right of access – you have the right to request a copy of the information that we hold about you.
- Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
- Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
- Right to restriction of processing – where certain conditions apply you have a right to restrict the processing.
- Right of portability – you have the right to have the data we hold about you transferred to another organisation.
- Right to object – you have the right to object to certain types of processing such as direct marketing.
- Right to object to automated processing, including profiling – you also have the right not to be subject to the legal effects of automated processing or profiling.
In the event that The Practice refuses your request under rights of access, we will provide you with a reason as to why, which you have the right to legally challenge. At your request The Practice can confirm what information it holds about you and how it is processed.
10 – You can request the following information:
- Identity and the contact details of the person or organisation (The Practice) that has determined how and why to process your data.
- Contact details of the data protection officer, where applicable.
- The purpose of the processing as well as the legal basis for processing.
- If the processing is based on the legitimate interests of The Practice and information about these interests.
- The categories of personal data collected, stored and processed.
- Recipient(s) or categories of recipients that the data is/will be disclosed to.
- How long the data will be stored.
- Details of your rights to correct, erasure, restrict or object to such processing.
- Information about your right to withdraw consent at any time.
- How to lodge a complaint with the supervisory authority (ICO).
- Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
- The source of personal data if it wasn’t collected directly from you.
- Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.
11 – To access what personal data is held, identification will be required
The Practice will accept the following forms of identification (ID) when information on your personal data is requested: a copy of your driving licence, passport, birth certificate and a utility bill not older than three months. A minimum of one piece of photographic ID listed above and a supporting document is required. If The Practice is dissatisfied with the quality, further information may be sought before personal data can be released. All requests should be made by emailing email@example.com or firstname.lastname@example.org.
12 – Complaints
In the event that you wish to make a complaint about how your personal data is being processed by The Practice you have the right to complain to us. If you do not get a response within 30 days, you can complain to the ICO.
The details for each of these contacts are:
Felicity Bertin, Telephone 07970 807625 or email email@example.com
Luci Lishman, Telephone 07795 366251 or email firstname.lastname@example.org
ICO, Wycliffe House, Water Lane, Wilmslow, SK9 5AF Telephone 0303 123 1113 or email: https://ico.org.uk/global/contact-us/email/