When you supply your personal details to this clinic they are stored and processed for 4 reasons (the bits in bold are the relevant terms used in the General Data Protection Regulation – ie 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 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.
4. Provided we have your consent, we may occasionally send you general health information in the form of articles, advice or newsletters. You may withdraw this consent at any time – just let us know by any convenient method.
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. In the case of electronic records, we will 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. Paper files will be disposed of securely as set out above.
Your records are stored:
on paper, in locked filing cabinets, and the offices are always locked and alarmed out of working hours.
electronically (“in the cloud”), using Cliniko and Mailchimp (an email service provider). These providers have given us their assurances that they are fully compliant with the General Data Protection Regulations. Access to this data is password protected, and the passwords are changed regularly.
on our office computers. These are password-protected, backed up regularly, and the office(s) are locked and alarmed out of working hours.
We will never share your data with anyone who does not need access without your written consent. Only the following people/agencies will have routine access to your data:
Cliniko - the medical records service who store and process our files
Mailchimp – send and process follow ups to see how you are doing or if you miss your appointment, and promotional material if you have consented to it.
Wix and 123 Formbuilder - via our website to process online patient forms
Your practitioner(s) in order that they can provide you with treatment
Our reception staff, because they organise our practitioners’ diaries, and coordinate appointments and reminders (but they do not have access to your medical history or sensitive personal information)
Other administrative staff, such as our bookkeeper. Again, administrative staff will not have access to your medical notes, just your essential contact details.
From time to time, we may have to employ consultants to perform tasks which might give them access to your personal data (but not your medical notes). We will ensure that they are fully aware that they must treat that information as confidential, and we will ensure that they sign a non-disclosure agreement.
You have the right to see what personal data of yours we hold, and you can also ask us to correct any factual errors. You may request a copy of your data at any time. Please make such a request in writing or by email to the Data Protection Officer, whose details are shown above. Please provide the following information: your name, address, telephone number, email address and details of the information you require. We will need to verify your identity so we may ask for a copy of your passport, driving license and/or recent utility bill. 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”. Here are the details you need for that:
Anthony Bolton 16 Story Lane, Broadstone, Dorset, BH18 8EQ
Email: firstname.lastname@example.org Tel: 01202989159
If you are not satisfied with our response, then you have the right to raise the matter with the Information Commissioner’s Office.