(Why we collect your personal data and what we do with it)
When you supply your personal details to this clinic, your data will be stored (in the United Kingdom only) and processed for the following 4 reasons. (Relevant terms used in the General Data Protection Regulations are in bold)
- We need to collect personal information about your health in order to provide you with the best possible treatment. We will only collect and record what is relevant and necessary for your treatment. Your requesting treatment and our agreement to provide that care constitutes a ‘Contract’.
- We have a ‘Legitimate Interest’ in collecting that information, because without it we couldn’t do our job effectively and safely. We also have a ‘Legitimate Interest’ in making CCTV recordings in the public parts of our building, to help keep visitors safe and our property secure.
- 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 constitutes your ‘Legitimate Interest’.
- Provided we have the explicit ‘Consent’ of new clients (attending the practice for the first time after 25th May 2018), we may occasionally send out practice news, advice or general health information by email. Under the Information Commissioner’s Office ‘soft opt-in’ guidelines, we are permitted to email clients who were customers of the practice before the implementation of the May ’18 GDPR laws in the above manner without their explicit consent, through the legal basis of mutual ‘Legitimate Interest’. However, all our clients have the right to ask to stop receiving any such emails – just let us know by any convenient method and at any time.
We have a ‘Legal Obligation’ to retain your records for 8 years after your most recent appointment (or until you reach the age of 25, if this is longer), after which your electronic records will be deleted and your paper records securely destroyed.
Your records are stored:
- on paper, in locked filing cabinets. The clinic is always locked out of working hours.
- on our office computers. These are password-protected and backed up regularly.
- CCTV records are held for 4 weeks in a secured part of the premises before being destroyed.
We will never share your data with anyone who does not need access, without your written consent. Everyone who has access to your data is pre-vetted and has signed an integrity and confidentiality agreement. Only the following people/agencies will have routine access to your data:
- Clinic Practitioner(s) in order that they can provide you with treatment.
- Our reception staff, because they organise our practitioners’ diaries, coordinate appointments and reminders, type letters, process payments and store and manage files.
- Other administrative staff may have access to your essential contact details but not your medical records.
- We may use fully GDPR compliant third-party organisations to co-ordinate and send messages, so your name and email address may be saved on their server.
As part of our obligations as healthcare practitioners, there may be circumstances related to your treatment, ongoing care or medical diagnosis that will require the sharing of your medical records with other healthcare practitioners eg GP’s, consultants, surgeons and/or medical insurance companies. Where this is required we will always discuss it with you first, unless we are under a ‘Legal Obligation’ to comply.
From time to time, we may have to employ a third party (eg IT 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 have signed a non-disclosure agreement.
You have a right to request (in writing) that we transfer the data we hold about you to another organisation.
You have the right to see what personal data of yours we hold and you can also ask us to correct any factual errors. If you wish to have a copy of the data we hold, please ask for a Data Access Request Form. 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.
If you feel that we are mishandling your personal data in some way, you have the right to complain.
Complaints need to be sent – by letter or email to:
The Data Controller, The Broad Street Practice Ltd, 20/21 Broad Street, Stamford, Lincs PE9 1PG firstname.lastname@example.org
If you are not satisfied with our response, then you have the right to raise the matter with the
Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF