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Davies Chi­ro­prac­tic patient pri­vacy statement

Davies Chi­ro­prac­tic is aware of its oblig­a­tions under the Gen­eral Data Pro­tec­tion Reg­u­la­tion (GDPR) and is com­mit­ted to pro­tect­ing the pri­vacy and secu­rity of your per­sonal infor­ma­tion. This pri­vacy notice describes, in line with GDPR, how we col­lect and use per­sonal data about you dur­ing and after your time as a patient of this clinic. It also sets out how we use that infor­ma­tion, how long we keep it for and other rel­e­vant infor­ma­tion about your data.

This notice applies to cur­rent and for­mer patients.


Data con­troller details

The Clinic is a data con­troller, mean­ing that it deter­mines the processes to be used when using your per­sonal data. Our con­tact details are as fol­lows: Davies Chiropractic Biz Space, Aerodrome Studios A43 & A44, 2-8 Airfield Way, Christchurch, BH23 3TS


Data pro­tec­tion principles

In relation to your personal data, we will comply with data protection law. This says that the personal information we hold about you must be: processed fairly, law­fully and in a clear, trans­par­ent way

col­lected only for valid rea­sons that we find proper for the course of your time as a patient and not used in any way that is incom­pat­i­ble with those pur­pos­es only used in the way that we have told you about ac­cu­rate and up to date

kept only as long as is nec­es­sary for the pur­poses we out­line process it in a way that ensures it will not be used for any­thing that you are not aware of or have con­sented to (as appro­pri­ate), lost or destroyed kept securely.


Types of infor­ma­tion we hold about you

Per­sonal data or infor­ma­tion means any infor­ma­tion about an indi­vid­ual from which that per­son can be iden­ti­fied. It does not include data where the iden­tity has been removed.

We hold many types of data about you, including :

your per­sonal details includ­ing your name, address, date of birth, email address, phone num­bers­ gen­der mar­i­tal sta­tu­s oc­cu­pa­tion­ num­ber and age of chil­dren­ per­sonal med­ical or health infor­ma­tion, includ­ing past med­ical his­to­ry­ in­for­ma­tion con­cern­ing exam­i­na­tion and treat­ment at your first and sub­se­quent vis­its­ bank­ing or finan­cial infor­ma­tion (e.g. card pay­ment receipts)letters of refer­ral to or from the clinic regard­ing your treat­ment with us.

Spe­cial cat­e­gories of data

There are “spe­cial cat­e­gories” of more sen­si­tive per­sonal data which require a higher level of pro­tec­tion, such as infor­ma­tion about a person’s health or sex­ual orientation.

We will use your spe­cial cat­e­gory data (health) :

· to ensure the care you receive at the clinic is appro­pri­ate to your condition

· to deter­mine rea­son­able adjust­ments that should be made for access to the clinic or to treatment

We must process spe­cial cat­e­gories of data in accor­dance with more strin­gent guide­lines. We will process spe­cial cat­e­gories of data when the fol­low­ing applies:

· you have given explicit con­sent to the pro­cess­ing (on our con­sent form)

· we must process the data in order to carry out our legal obligations

· we must process data for rea­sons of sub­stan­tial pub­lic interest

Less com­monly, we may process this type of infor­ma­tion where it is needed in rela­tion to legal claims or where it is needed to pro­tect your inter­ests (or some­one else’s inter­ests) and you are not capa­ble of giv­ing your con­sent, or where you have already made the infor­ma­tion public.

As with all cases of seek­ing con­sent from you, you will have full con­trol over your deci­sion to give or with­hold con­sent and there will be no con­se­quences where con­sent is with­held. Con­sent, once given, may be with­drawn at any time. There will be no con­se­quences where con­sent is withdrawn.


How we col­lect your data

We col­lect data about you in a vari­ety of ways and this will usu­ally start when you make an enquiry to the clinic and con­tinue when you attend your first and sub­se­quent appoint­ments. At this clinic, we keep paper and elec­tronic records. Infor­ma­tion we write down on paper may be trans­ferred to our elec­tronic sys­tem. We may receive infor­ma­tion about you from your GP or other health care provider regard­ing your refer­ral or, with your per­mis­sion, addi­tional infor­ma­tion that will help us con­tinue with your treat­ment. We may also hold the results of tests that you have under­taken and that are rel­e­vant to your treat­ment with the clinic. Per­sonal data is kept secure in line with GDPR reg­u­la­tions at our clinic.

        


Why we process your data (How we will use infor­ma­tion about you)

The law on data pro­tec­tion allows us to process your data for cer­tain rea­sons only, these are clas­si­fied as legit­i­mate inter­ests. Most com­monly, we will use your per­sonal infor­ma­tion in the fol­low­ing circumstances:

· in order for us to carry out our con­tract with you (your request­ing treat­ment and our agree­ment to pro­vide it con­sti­tutes a con­tract) which will include con­firm­ing appoint­ments, inform­ing you of changes to appoint­ments or clinic arrange­ments, changes to facil­i­ties or ser­vices at the clinic.

· in order to pro­vide you with the best pos­si­ble treat­ment by record­ing health and treat­ment infor­ma­tion which would be in your best interest.

· in order to carry out legally required duties such as those required by me by my gov­ern­ment appointed regulator

· where it is nec­es­sary for our legit­i­mate inter­ests and your inter­ests and fun­da­men­tal rights do not over­ride those interests

We may use your per­sonal infor­ma­tion in these rare situations :

· where we need to pro­tect your or some­one else’s interests

· where it is needed in the pub­lic inter­est or for offi­cial purposes

Sit­u­a­tions in which we will use your per­sonal information

We need all the cat­e­gories of infor­ma­tion to pri­mar­ily allow us to per­form our con­tract of treat­ment with you and to enable us to com­ply with legal obligations.

 


If you do not pro­vide your data to us

One of the rea­sons for pro­cess­ing your data is to allow us to carry out our duties in line with your con­tract of care with us. If you do not pro­vide us with the data needed to do this, we will be unable to per­form that care to ensure your best inter­ests are being main­tained. We may also be pre­vented from con­tin­u­ing with your treat­ment with us due to our legal obligations.

Change of purpose

We will only use your per­sonal infor­ma­tion for the pur­poses for which we col­lected it unless we rea­son­ably con­sider that we need to use it for another rea­son and that rea­son is com­pat­i­ble with the orig­i­nal pur­pose. If we need to use your per­sonal infor­ma­tion for an unre­lated pur­pose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your per­sonal infor­ma­tion with­out your knowl­edge or con­sent, in com­pli­ance with the above rules, where this is required or per­mit­ted by law.

Auto­mated deci­sion making

No deci­sion will be made about you solely on the basis of auto­mated deci­sion mak­ing (where a deci­sion is taken about you using an elec­tronic sys­tem with­out human involve­ment) which has a sig­nif­i­cant impact on you.

 

Shar­ing your data

Your data will be shared with col­leagues within the clinic but only where it is nec­es­sary for them to under­take their duties. This includes, for exam­ple, other Chi­ro­prac­tors and Phys­io­ther­a­pists work­ing for, at or on behalf of the clinic, recep­tion and office staff.

We may share your data with third par­ties in order to facil­i­tate a refer­ral to another self- employed Chi­ro­prac­tor, Physio, health­care prac­ti­tioner, for fur­ther inves­ti­ga­tions or to keep your GP informed about your progress with treatment.

We may also share your data with third par­ties as part of a clinic sale or restruc­ture, or for other rea­sons to com­ply with a legal oblig­a­tion upon us. We would always keep you informed of these situations.


Trans­fer­ring infor­ma­tion out­side the EU

We do not share your data with bod­ies out­side of the Euro­pean Eco­nomic Area.


Data Secu­rity — Pro­tect­ing your data

We have put in place mea­sures to pro­tect the secu­rity of your infor­ma­tion against acci­den­tal loss or dis­clo­sure, alter­ation, unau­tho­rised access, destruc­tion or abuse. We have imple­mented processes to guard against such. In addi­tion, we limit access to your per­sonal infor­ma­tion to those employ­ees, agents, con­trac­tors and other third par­ties who have a busi­ness need to know. They will only process your per­sonal infor­ma­tion on our instruc­tions and they are sub­ject to a duty of confidentiality.

Where we share your data with third par­ties, we pro­vide writ­ten instruc­tions to them to ensure that your data is held securely and in line with GDPR require­ments. Third par­ties must imple­ment appro­pri­ate tech­ni­cal and organ­i­sa­tional mea­sures to ensure the secu­rity of your data.


How long we keep your data for

In line with data pro­tec­tion prin­ci­ples, we only keep your data for as long as we need it for, which will be at least for the dura­tion of your being a patient with us and we are legally required, by the Chi­ro­prac­tic reg­u­la­tor, to keep this data for eight years after your time as a patient has ended. To deter­mine the appro­pri­ate reten­tion period for per­sonal data beyond eight years we con­sider the amount, nature, and sen­si­tiv­ity of the per­sonal data, the poten­tial risk of harm from unau­tho­rised use or dis­clo­sure of your per­sonal data, the pur­poses for which we process your per­sonal data and whether we can achieve those pur­poses through other means and the applic­a­ble legal requirements.

Once we no longer have a law­ful use for retain­ing your infor­ma­tion, we will dis­pose of it in a secure man­ner that main­tains data security.

In some cir­cum­stances we may anonymise your per­sonal infor­ma­tion so that it can no longer be asso­ci­ated with you, in which case we may use such infor­ma­tion with­out fur­ther notice to you.

Your duty to inform us of changes

It is impor­tant that the per­sonal infor­ma­tion we hold about you is accu­rate and cur­rent. Please keep us informed if your per­sonal infor­ma­tion changes dur­ing your time as a patient with us.


Your rights in rela­tion to your data

The law on data pro­tec­tion gives you cer­tain rights in rela­tion to the data we hold on you :

· the right of access. You have the right to access the data that we hold on you. To do so, you should make a sub­ject access request. Find out how to do this from Davies Chiropractic Biz Space, Aerodrome Studios A43 & A44, 2-8 Airfield Way, Christchurch, BH23 3TS

· the right for any inac­cu­ra­cies to be cor­rected. If any data that we hold about you is incom­plete or inac­cu­rate, you can require us to cor­rect it.

· the right to be informed. This means that we must tell you how we use your data, and this is the pur­pose of this pri­vacy notice. We also must inform you of any changes to how we use your data.

· the right to have infor­ma­tion deleted. If you would like us to stop pro­cess­ing your data, you have the right to ask us to delete it from our sys­tems where you believe there is no rea­son for us to con­tinue pro­cess­ing it.

· the right to restrict the pro­cess­ing of the data. For exam­ple, if you believe the data we hold is incor­rect, we will stop pro­cess­ing the data (whilst still hold­ing it) until we have ensured that the data is correct.

· the right to porta­bil­ity. You may request trans­fer the data that we hold on you for your own purposes.

If you want to access your data, review, ver­ify or cor­rect your data, request we erase your per­sonal infor­ma­tion, object to the pro­cess­ing of your per­sonal data, or request that we trans­fer a copy of your per­sonal infor­ma­tion to another party, please con­tact Davies Chiropractic Biz Space, Aerodrome Studios A43 & A44, 2-8 Airfield Way, Christchurch, BH23 3TS in writing.

Fees

You will not have to pay a fee to access your per­sonal infor­ma­tion (or to exer­cise any of the other rights). How­ever, we may charge a rea­son­able fee for a sec­ond or sub­se­quent copy of infor­ma­tion or if your request for access is clearly unfounded or exces­sive. Alter­na­tively, we may refuse to com­ply with the request in such circumstances.

 


What we may need from you

We may need to request spe­cific infor­ma­tion from you to help us con­firm your iden­tity and ensure your right to access the infor­ma­tion (or to exer­cise any of your other rights). This is a secu­rity mea­sure to ensure that per­sonal infor­ma­tion is not dis­closed to any per­son who has no right to receive it.

Right to with­draw consent

Where you have pro­vided con­sent to the col­lec­tion, pro­cess­ing and trans­fer of your data, you have the right to with­draw that con­sent at any time. There will be no con­se­quences for with­draw­ing your con­sent. How­ever, in some cases, we may con­tinue to use the data where so per­mit­ted by hav­ing a legit­i­mate legal rea­son for doing so.

To with­draw con­sent, Davies Chiropractic Biz Space, Aerodrome Studios A43 & A44, 2-8 Airfield Way, Christchurch, BH23 3TS


Mak­ing a complaint

If you have any ques­tions about this Pri­vacy Notice or how we han­dle your infor­ma­tion, please con­tact the Clinic’s Data Pro­tec­tion Davies Chiropractic Biz Space, Aerodrome Studios A43 & A44, 2-8 Airfield Way, Christchurch, BH23 3TS

 

You have the right to make a com­plaint at any time to the super­vi­sory author­ity in the UK for data pro­tec­tion mat­ters, the Infor­ma­tion Commissioner’s Office (ICO).

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What are cookies?

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The types of cookies that we use

This section sets out information about the cookie technology that we use on our site for which we are responsible. Where 'personal data' is processed by these cookies, Pinsent Masons LLP is the 'data controller' of that information, within the meaning of applicable data protection legislation. For an explanation of the meaning of these and other data protection legislation terms, and for comprehensive information about our responsibilities when handling personal data - including transfers of personal data across the Pinsent Masons business worldwide - and your rights in respect of any personal information of yours that we process, please see our Privacy Policy.

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Basic performance – 'necessary' or 'essential' cookies

We use essential cookies to operate the core functions of our website, so that you may visit and move around it, and use its features. We do not require your consent to use these cookies but you may be able to block these cookies yourself on your device/browser (see section 4 of this Policy). However, without these cookies, our site is unlikely to work as you would expect and certain services that you may ask for, for example, signing into your online account, cannot be provided.

 

Where we process 'personal data' using these essential cookies, we do so on the basis of our legitimate interests to provide a website for visitors to use and to promote our business.

 

Purpose of essential cookies

The essential cookies that we use on our website are technically necessary for the site to function properly.
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Data processed by essential cookies

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We process data collected by essential cookies on our own servers. Data collected by certain essential cookies may be collected, in aggregate form only from which no one visitor to our site can be identified or distinguished from another, by our third party essential cookie providers such as Sitecore, for their own purposes.  

        

Transfers

Our global presence means that your personal information may be transferred across the business worldwide due, for example, to our shared IT systems and datacentres, and cross-border working practices. 

        

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These cookies work by using a distinctive sequence of characters from which your browser or device can be identified ('unique ID'), which, for example, can be used by us to recognise the date and time of your visit(s) to our site. Our analytics cookies may also collect information about your browser type and settings, device type and settings, operating system and mobile network. This information is used to distinguish you from other visitors to our site, but it cannot be used to identify you as a named individual.

 

We will only set these types of cookies where you have provided us with your consent to do so by either choosing to 'Allow all cookies' or by adjusting your cookie settings via the 'Your cookies settings', above. Where we process your personal information using these types of cookies, we do so on the basis of that consent.

Rejecting our analytics cookies will prevent us from collecting the data described above to improve our site for you and other visitors. The performance and functionality of our site will not be affected.

 

The analytics cookies that we use

 

Google Analytics

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We process the data collected by these Google Analytics cookies. Google Analytics may provide us with technical support. Data may be collected - in aggregate form only from which no one visitor to our site can be identified or distinguished from another - by Google Analytics to help improve Google Analytics' products and services.
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Social media cookies

We have configured the social media plug-ins on our website to only set cookies on devices used by logged-in members of those social media platforms. For example, we may advertise the services that we provide and job opportunities on certain third party websites such as LinkedIn. We use cookies from those third parties' sites on our own website to:

 

• provide us with anonymised demographics and browsing activity information of the logged-in visitors to our own website;

 

• help us to tailor our advertising on the websites of those third parties to previous logged-in visitors to certain pages of our own site; and

 

• help us measure the effectiveness of our advertising.

 

These cookies work by using a distinctive sequence of characters from which your browser or device can be identified ('unique ID'). Social media cookies may also collect information about your browser type and settings, device type and settings, operating system and mobile network. This information is used to distinguish you from other visitors to our site, but it cannot be used to identify you as a named individual.

 

We will only set these types of cookies where you have provided us with your consent to do so by either choosing to 'Allow all cookies' or by adjusting your cookie settings via the 'Your cookies settings', above. Where we process your personal information using these types of cookies, we do so on the basis of that consent.

 

Rejecting these cookies will prevent us from relating your visits to our website to our LinkedIn marketing campaigns. It will also prevent any cookies that you have given cons

 

Cookie set by third parties 

'Third party cookies' are cookies set by a domain other than the one that you are visiting. When you visit our website, third party organisations may place cookies on your browser, even if you are not a logged-in member of those organisations. This is because third party cookies do not require you to actively engage with the third party's content or visit their site, just load a page on which the third party's technology sits. For example, we use third party technologies such as video and audio hosting platforms to enable you to watch videos and listen to podcasts on our website. The providers of these technologies may deploy cookies to your browser when you visit the pages on our site where we are using their technologies.

 

These cookies may inform the third party organisations about your visit to our site which may be used by those organisations to deliver targeted messages and advertising to you. In all cases, we do not set these cookies and we have no access to the information that they gather. Such cookies are subject to the third party organisations' own cookie policies.

 

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