Scope
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 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 – The Vitality Practice, based at The Kailash Centre, 7 Newcourt Street, London NW8 7AA 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/.
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. 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 and/or medical insurance companies. Where this is
required we will always inform you first unless we are under a legal obligation
to comply.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. e) Osteopaths’ website uses cookies, which is a string of information that
a website stores on a visitor’s computer, and that the visitor’s browser
provides to the website each time the visitor returns. Osteopaths’ website
visitors who do not wish to have cookies placed on their computers should set
their browsers to refuse cookies before using Osteopaths’ website.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 info@thevitalitypractice.co.uk or by phoning +44 (0)
07808 670834 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:
Denise Cuddigan Telephone 07808 670834, or email info@thevitalitypractice.com or, mail to Denise Cuddigan, The Kailash Centre, 7 Newcourt street, London NW8 7AA.
ICO
Wycliffe House, Water Lane, Wilmslow,
SK9 5AFTelephone +44 (0) 303 123
1113 or email: https://ico.org.uk/global/contact-us/email/
The Vitality Practice, The Kailash Centre, 7 Newcourt Street, London NW8 7AA Tel: 07808 67083 Privacy Policy