PRIVACY NOTICE in compliance with General Data Protection Regulation (GDPR) (EU) 2016/679
Why Nunhead Osteopaths Ltd collect your personal data and what we do with it.
When you supply your personal details to this clinic they are stored and processed for three reasons (the bits in bold are the relevant terms used in the Data Protection Act 2018, which includes the General Data Protection Regulation – i.e. the law):
1. We need to collect personal information about your health in order to provide you with the best possible treatment. Your requesting treatment and our agreement to provide that care constitutes a contract. You can, of course, refuse to provide the information, but if you were to do that we would not be able to provide treatment.
2. We have a “Legitimate Interest” in collecting that information because without it we couldn’t do our job effectively and safely.
3. We also think that it is important that we can contact you in order to arrange or confirm your appointments with us or to update you on matters related to your medical care. This again constitutes “Legitimate Interest”, but this time it is your legitimate interest.
We have a legal obligation to retain your records for 8 years after your most recent appointment (or age 25, if this is longer), but after this period you can ask us to delete your records if you wish. Otherwise, we may retain your records indefinitely in order that we can provide you with the best possible care should you need to see us at some future date.
As part of our obligations as primary healthcare practitioners, there may be circumstances related to your treatment, on-going care or medical diagnosis that will require the sharing of your medical records with other healthcare practitioners e.g GPs, consultants, surgeons, our regulatory body the General Osteopathic Council and/or medical insurance companies. Where this is required we will always inform you first unless we are under a legal obligation to comply.
We do not engage in any direct marketing and will not use your details for promotional purposes. We will not use your contact details to contact you aside from arranging appointments or following up on previous treatment in order to check on your well-being. We will only collect the information needed so that we can provide you with the services you require from us, the business does not sell or broker your data.
Your personal medical records are stored on paper, in locked filing cabinets, and the office is always locked and alarmed out of working hours. They are only accessible by osteopaths who work at the practice.
Your contact details will also appear in our electronic diary system provided by our off-site UK based reception service, Clinic Appointments, who assure us they are fully GDPR compliant: http://www.clinicappointments.com/privacy-policy/ This is password-protected and only accessible by the osteopaths who work in the practice and Clinic Appointments.
We may also retain emails that we have exchanged on our work-related computers. Access to this data is password protected. Emails are also stored electronically (“in the cloud”) and accessed via cPanel which is supplied by Krystal.co.uk who hosts our website which receives booking requests including contact details and is fully GDPR compliant. Access to this data is password protected. Their privacy policy can be found at https://krystal.co.uk/terms
We will never share your data with anyone who does not need access without your consent. Only the following people/agencies will have routine access to your data:
- Your practitioner(s) in order that they can provide you with treatment
- Other practitioners who staff the practice in their role in organizing practitioners’ diaries, and coordinating appointments
- Your contact details will be accessible by staff at our reception service, Clinic Appointments.
You have the right to see what personal data of yours we hold, and you can also ask us to correct any factual errors. Provided the legal minimum period has elapsed, you can also ask us to erase your records.
We want you to be absolutely confident that we are treating your personal data responsibly, and that we are doing everything we can to make sure that the only people who can access that data have a genuine need to do so.
Of course, if you feel that we are mishandling your personal data in some way, you have the right to complain. Complaints need to be sent to what is referred to in the jargon as the “Data Controller”:
Nancy Nunn
020 7733 5633
55 Hichisson Rd
London
SE15 3AN
If you are not satisfied with our response, then you have the right to raise the matter with the Information Commissioner’s Office.