Scope
This notice 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
- Your Practice
Bingley
Osteopathic Practice,
based at
Prospect
House, 177 Bradford Road, Bingley, BD16
1AH,
which hereafter for the purposes 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 health conditions. 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 be pleased to provide more details.
3
- Personal Data
a)
For the purposes of providing treatment, Osteopaths 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 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 who have all signed an integrity and confidentiality
agreement. To be able to process your personal data it is a condition
of any treatment that you give your 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.
b)
For marketing purposes, the Osteopaths may also use the contact
details provided by you to respond to your enquiries, including
making telephone contact 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 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 its
patients in the capacity of data processor, when we may promote other
practitioners based at our premises, who may not be employed by us.
Osteopaths do 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 phone calls 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 broker your data.
4
- 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.
5
- Legitimate interests pursued by Osteopaths
To
promote treatments for patients with 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 the purposes 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 treatment will have access to your patient
records, although our administration team will have access to your
contact details so that they can make appointments and manage your
account. Osteopaths 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.
8
- Retention Policy
Osteopaths
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 us to meet our future obligations
to you, 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
All
Data is held in the United Kingdom. Osteopaths does not store
personal data outside the EEA.
10
- Your rights as a data subject
At
any point whilst Osteopaths 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 Osteopaths 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 Osteopaths can
confirm what information it holds about you and how it is processed.
11
- You can request the following information:
-
Identity
and the contact details of the person or organisation (Osteopaths)
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 Osteopaths
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.
12
- To access what personal data is held, 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 of photographic ID
listed above and a supporting document is required. If Osteopaths is
dissatisfied with the quality, further information may be sought
before personal data can be released.
All
requests should be made to sue.austin.osteo@gmail.com
or
by phoning +44 (0) 7855085060
or writing to us at the address further below.
13
Complaints
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.
The
details for each of these contacts are:
Sue
Austin,
Prospect
House Clinic, 177 Bradford RD., Bingley, BD16 1AH
Telephone
07855085060
or
email:
sue.austin.osteo@gmail.com
ICO
Wycliffe
House, Water Lane, Wilmslow, SK9 5AF
Telephone
+44 (0) 303 123 1113 or email:
https://ico.org.uk/global/contact-us/email/