Privacy, GDPR and Cookie 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 Privacyand 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 theEEA.
1 - Your Practice HoddesdonOsteopathic & Sports Injury Clinic, based at 21 The Drive Hoddesdon Herts EN11 9JB, which hereafter for thepurposes of this Privacy Notice will be referred to as the Osteopaths, is pleased to provide the following information:
2 - Who we are
The Osteopaths diagnose and treat healthconditions. Treatments are carried out in accordance with the Institute of Osteopathy’s patient charter http://www.iosteopathy.org/osteopathy/the-patient-charter/. The practice may also provide other treatments, about which our staff will bepleased to provide more details.
3 - Personal Data
a) For the purposes of providingtreatment, Osteopaths may require detailed medical information. We will only collect what is relevant and necessary for your treatment. When you visit ou rpractice, we will make notes which may include details concerning your medication, treatment and other issues affecting your health. This data is always held securely, is not shared with anyone not involved in your treatment,although for data storage purposes it may be handled by pre-vetted staff whohave all signed an integrity and confidentiality agreement. To be able to process your personal data it is a condition of any treatment that you giveyour explicit consent to allow Osteopaths to document and process your 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 or other information concerning your treatment. As part ofour obligations as primary healthcare practitioners there may be circumstances related to your treatment, on-going care or medical diagnosis that will requirethe sharing of your medical records with other healthcare practitioners e.g GPs,consultants, surgeons and/or medical insurance companies. Where this isrequired we will always inform you first unless we are under a legal obligationto comply.
b) For marketing purposes, the Osteopaths may also use the contact detailsprovided by you to respond to your enquiries, including making telephone contact and emailing information to you which the practice believes may be ofinterest to you.
c) In making initial contact with the practice you consent to Osteopaths 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. Osteopaths may occasionally also act on behalf of itspatients in the capacity of data processor, when we may promote other practitioners based at our premises, who may not be employed by us. Osteopathsdo not broker your data and you can ask to be removed from our marketing database by emailing or phoning 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 marketing forms and surveys you complete, from records of our correspondence and phonecalls and details of your visits to our website, including but not limited to,personally identifying information like Internet Protocol (IP) addresses.
f) Osteopaths will only collect the information needed so that we can provide you with the services you require, the business does not sell or brokeryour data.
4 - Legal basis for processing anypersonal data
To meet our contractual obligations obtained from explicit Patient Consent and legitimate interest to respond toenquiries concerning the services provided.
5 - Legitimate interests pursued byOsteopaths
To promote treatments for patientsw ith all types of health problems indicated for osteopathic care.
6 – Consent
Through agreeing to this privacy notice you are consenting to Osteopaths processing your personal data for thepurposes outlined. You can withdraw consent at any time by using the postal,email address or telephone number provided at the end of this Privacy Notice.
7 – Disclosure
Osteopaths will keep your personal information safe and secure, only staff engaged in providing your treatmentwill have access to your patient records, although our administration team willhave access to your contact details so that they can make appointments and manage your account. Osteopaths will not disclose your Personal Informationunless 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 todetect, prevent or mitigate fraud or security or technical issues; or toprotect against imminent harm to the rights, property or safety of its staff.
8 - Retention Policy
Osteopaths will process personal data during the duration of any treatment and will continue to store only thepersonal data needed for eight years after the contract has expired to meet anylegal obligations. After eight years all personal data will be deleted, unlessbasic information needs to be retained by us to meet our future obligations toyou, such as erasure details. Records concerning minors who have received treatment will be retained until the child has reached the age of 25.
9 - Data storage
AllData is held in the United Kingdom. Osteopaths does not store personal dataoutside the EEA.
10 - Your rights as a data subject
At any point whilst Osteopaths are inpossession of, or processing your personal data, all data subjects have thefollowing rights:
· Right of access – you have the rightto request a copy of the information that we hold about you.
· Right of rectification – you have aright to correct data that we hold about you that is inaccurate or incomplete.
· Right to be forgotten – in certaincircumstances you can ask for the data we hold about you to be erased from ourrecords.
· Right to restriction of processing –where certain conditions apply you have a right to restrict the processing.
· Right of portability – you have theright to have the data we hold about you transferred to another organisation.
· Right to object – you have the rightto object to certain types of processing such as direct marketing.
· Right to object to automatedprocessing, including profiling – you also have the right not to be subject tothe legal effects of automated processing or profiling.
In the event that Osteopaths refuses your request under rights of access, wewill provide you with a reason as to why, which you have the right to legally challenge. At your request Osteopaths can confirm what information it holdsabout you and how it is processed.
11 - You can request the followinginformation:
· Identity and the contact details ofthe person or organisation (Osteopaths) that has determined how and why toprocess your data.
· Contact details of the data protection officer, where applicable.
· The purpose of the processing as wellas the legal basis for processing.
· If the processing is based on thelegitimate interests of Osteopaths and information about these interests.
· The categories of personal datacollected, stored and processed.
· Recipient(s) or categories ofrecipients 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 towithdraw consent at any time.
· How to lodge a complaint with thesupervisory 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 personaldata and the possible consequences of failing to provide such data.
· The source of personal data if itwasn’t collected directly from you.
· Any details and information of automated decision making,
such as profiling, and any meaningful informationabout the logic
involved, as well as the significance and expected consequencesof such
12 - To access what personal data isheld, identification will be required
Osteopaths 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 ofphotographic ID listed above and a supporting document is required. If Osteopaths is dissatisfied with the quality, further information may be soughtbefore personal data can be released. All requests should be made to email@example.com or by phoning +44 (0) 1992 460669 or writing to us at the address further below.
In the event that you wish to make a complaint about how your personal data is being processed by Osteopaths you have the right to complain to us. If you do not get a response within 30 days,you can complain to the ICO.
Thedetails for each of these contacts are:
Telephone 01992 460669 or email: firstname.lastname@example.org
Address:Hoddesdon Osteopathic & SportsInjury Clinic
21 The Drive Hoddesdon HertsEN11 9JB.ICO
Wycliffe House, Water Lane, Wilmslow,SK9 5AF Telephone +44 (0) 303 1231113 or email: https://ico.org.uk/global/contact-us/email/