Purpose of privacy notice
The processing of personal data is governed by the General Data Protection Regulation 2016/679 (the GDPR). This legislation will replace current data privacy law, giving more rights to you as an individual and more obligations to organisations holding your personal data.
One of the rights is a right to be informed, which means we have to give you even more information than we do now about the way in which we use, share and store your personal information.
This new privacy notice comes into effect and will be published on our website on 25 May 2018.
We are the Southview Clinic, 113 Wycombe Road, Marlow, Bucks. SL73JB. Alexandra and David Reynolds are the practitioners.
David Reynolds is our data controller. This means he decides how your personal data is processed and for what purposes.
Whose information does this privacy notice apply to?
This privacy notice applies to information we collect from:
What is personal data?
Personal data relates to a living individual who can be identified from that data. Identification can be by the information alone or in conjunction with any other information in the data controller’s possession or likely to come into such possession. Examples of personal data we may hold about you include your contact and appointment details.
Special category data is a sub-category of personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation. Examples of special category data we may hold about you include your patient notes.
How do we process your personal data?
We comply with our obligations under the GDPR by keeping personal data up to date; by storing and destroying it securely; by not collecting or retaining excessive amounts of data; by protecting personal data from loss, misuse, unauthorised access and disclosure and by ensuring that appropriate technical measures are in place to protect personal data. We use your personal data for the purposes set out below. Our lawful basis for processing this data is consent and legitimate interest.
1. We use your name, address, telephone number and email address to make and rearrange appointments. We are unable to send or receive encrypted emails so you should be aware that any emails we send or receive may not be protected in transit. We will also monitor any emails sent to us, including file attachments, for viruses or malicious software. Please be aware that you have a responsibility to ensure that any email you send us is within the bounds of the law.
2. We keep a permanent paper attendance register which records all appointments for patients attending our clinic to keep a record of when you were treated for tax purposes and to secure potential evidence in the event of a criminal prosecution, civil litigation, insurance claim or complaint to our regulatory bodies, the Chartered Society of Physiotherapists, the General Osteopathic Council, the British Acupuncture Council and the Acupuncture Association of Chartered Physiotherapists.
3. We may use your date of birth to help identify patients with the same name to avoid mistakes being made as to safe and appropriate treatment, for identification purposes if referring a patient to another health practitioner, and for identification purposes if writing to a registered medical practitioner so that they correctly identify the patient.
4. We use your presenting complaint and symptoms reported by you for the purposes of making a full diagnosis, formulating treatment strategy and treatment planning.
5. We use any relevant medical and family history you have told us for making a full diagnosis, formulating treatment strategy and treatment planning.
6. We use your GP’s name and address in the event that we need to contact your GP including in an emergency and because it is a mandatory requirement in the codes of conduct of our regulatory bodies..
7. We use our clinical findings about your health and wellbeing for making a full diagnosis, and formulating treatment strategy and treatment planning.
8. We keep a paper record of and refer to that record of any treatment given and details of progress of your case, including reviews of treatment planning to enable us to: review the full diagnosis, treatment strategy and planning; and to secure evidence in the event of criminal proceedings, civil litigation, an insurance claim or complaint.
9. We record and use any information and advice that we have given, especially when referring patients to any other health professional, to help you to receive the most appropriate treatment and to secure evidence in the event of criminal proceedings, civil litigation, an insurance claim or complaint.
10. We record any decisions made in conjunction with you to help you to receive the most appropriate treatment and to secure evidence in the event of criminal proceedings, civil litigation, an insurance claim or complaint.
11. We keep paper accident records for any patients, visitors or staff who are involved in accidents at our clinic in accordance with UK Health and Safety legislation including the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations (RIDDOR) to comply with the law and to secure evidence in the event of criminal proceedings, civil litigation, an insurance claim or complaint.
12. In the event of an adverse incident occurring to any of our patients we report the latter to our regulatory bodies and to our insurance company to enable the insurance company to deal with any potential claims and to help the those bodies to develop their safe practice guidelines, as well as providing research data and information for their insurers and other interested parties.
13. Where relevant we maintain paper records of the patient’s consent to treatment, or the consent of their next-of-kin in order to be able to prove that the patient (and/or parent/guardian/next of kin) has given informed consent to treatment to secure evidence in the event of a civil claim, criminal prosecution, insurance claim or complaint.
14. If we receive a complaint from a person, we make up a file containing the details of the complaint. This normally contains the identity of the complainant and any other individuals involved in the complaint.
We will only use the personal information we collect to process the complaint and to check on the level of service we provide. If a complainant doesn’t want information identifying him or her to be disclosed, we will try to respect that. However, it may not be possible to handle a complaint on an anonymous basis. We may need to provide personal information collected and processed in relation to complaints to our regulatory bodies or our insurance company.
We will keep personal information contained in complaint files in line with our retention policy. This means that information relating to a complaint will be retained for two years from closure. It will be retained in a secure environment and access to it will be restricted according to the ‘need to know’ principle.
Similarly, where enquiries are submitted to us we will only use the information supplied to us to deal with the enquiry and any subsequent issues and to check on the level of service we provide.
15. We use a third party, builtbyjay.com to host our website and maintain its security and performance. http/builtbyjay.com/contact
We keep your personal data for no longer than reasonably necessary.
We keep patient records for a period of 8 years for adults and up to the 25th birthday for a child, in accordance with our regulatory bodies Codes of Professional Conduct https://www.acupuncture.org.uk/public-content/effective-practice/bacc-professional-codes.html
Your paper records are stored in a locked cabinet in a locked room. Any electronic data we hold on you is stored on secure servers and any devices holding such data are password encrypted for practitioner use ie David or Alexandra Reynolds, only. Paper records will destroyed using GDPR compliant shredders.
At any time you may request that changes are made to your contact details. Unless subject to an exemption under the GDPR, you have certain rights with respect to your personal data as set out below.
For further details about these rights please see the Information Commissioner’s website at https://ico.org.uk/for-the-public/is-my-information-being-handled-correctly/
If we wish to use your personal data for a new purpose, not covered by this Privacy Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions. Where and whenever necessary, we will seek your prior consent to the new processing
To exercise all relevant rights, queries of complaints please in the first instance contact us at firstname.lastname@example.org
You can contact the Information Commissioners Office on 0303 123 1113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire. SK9 5AF.