The UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018 and the Privacy and Electronic Communications Regulations (PECR), seek to protect and enhance the rights of UK data subjects. These rights cover the safeguarding of personal data, protection against the unlawful processing of personal data and its storage within the UK.
1 - My Practice
CH Osteopathy, based at Avenue Tennis, Featherby Road, Gillingham, Kent, ME8 6AN, which hereafter for the purposes of this privacy notice will be referred to as CH Osteopathy, is pleased to provide the following information:
2 - Who we are
CH Osteopathy diagnoses and treats musculoskeletal conditions. Treatments are carried out in accordance with the Institute of Osteopathy’s patient charter http://www.iosteopathy.org/osteopathy/the-patient-charter/. CH Osteopathy also provides Sports Massage Therapy.
3 - Personal Data
a) For the purposes of providing treatment, CH Osteopathy may require detailed medical information. We will only collect what is relevant and necessary for your treatment. When you visit the practice, we will make notes which may include details concerning your health, medication, treatment and other issues affecting your musculoskeletal conditions. This data is always held securely and is not shared with anyone not involved in your treatment. To be able to process your personal data it is a condition of any treatment that you give your explicit consent to allow CH Osteopathy 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, CH Osteopathy 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 CH Osteopathy 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. CH Osteopathy 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. CH Osteopathy does 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) CH Osteopathy will only collect the information needed so that we can provide you with the services required.
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 CH Osteopathy
To promote treatments for patients with all types of musculoskeletal problems including back pain and neck pain, tennis elbow, frozen shoulders, sciatica, headaches, sports injuries, and other degenerative conditions.
6 - Consent
Through agreeing to this privacy notice you are consenting to CH Osteopathy 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
CH Osteopathy will keep your personal information safe and secure and only the practitioner 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. CH Osteopathy 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
CH Osteopathy 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 years.
9 - Data storage
Treatment notes are stored:
On paper – for records created up to August 2017, in locked filing cabinets within the clinic room which is always locked and alarmed out of working hours.
Electronically – for records created from August 2017 using specialist medical records service Cliniko. Patient records are stored on Cliniko, a cloud based solution located in Australia. Cliniko has signed a contract with CH Osteopathy to protect patient data subject rights in accordance with GDPR. Access to this data is via 2 factor authentication using a smart phone generated one-time only log in code and password and passwords are changed regularly.
CH Osteopathy will never share your data with anyone who does not need access and without your written consent.
10 - Your rights as a data subject
At any point whilst CH Osteopathy are in possession of, or processing your personal data, all data subjects have the following rights:
Right to information – you can ask for information about what data is being processed and the rationale for such processing.
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 CH Osteopathy 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 CH Osteopathy 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 (CH Osteopathy) 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 CH Osteopathy 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
CH Osteopathy 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 CH Osteopathy is dissatisfied with the quality, further information may be sought before personal data can be released. All requests should be made to email@example.com or by phoning +44 (0)1634 386188 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 CH Osteopathy 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:
CH Osteopathy, Avenue Tennis, Featherby Road, Gillingham, Kent, ME8 6AN Telephone +44 (0)1634 386188 or email: firstname.lastname@example.org
Wycliffe House, Water Lane, Wilmslow, SK9 5AF Telephone +44 (0) 303 123 1113 or email: https://ico.org.uk/global/contact-us/email/