GDPR 2018 PRIVACY NOTICE
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 – Minerva Osteopathy, based at 2 Marlow Road, Stokenchurch which hereafter for the purposes of this Privacy Notice will be referred to as the Minerva Osteopathy, is pleased to provide the following information:
2 – Who we are
Minerva Osteopathy 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/. The practice may also provide
other treatments, about which our staff will be pleased to provide more details.
3 – Personal Data
a) For the purposes of providing treatment, Minerva
Osteopathy 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 Minerva Osteopathy 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, Minerva Osteopathy 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 Minerva
Osteopathy 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. Minerva Osteopathy 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. Minerva
Osteopathy 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) Minerva Osteopathy’ 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. WordPress.org
uses cookies to help Minerva Osteopathy to identify and track visitors and
their website access preferences. Minerva Osteopathy’s website visitors who do
not wish to have cookies placed on their computers should set their browsers to
refuse cookies before using Minerva Osteopathy’s website.f) Minerva Osteopathy 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 Minerva Osteopathy 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
Minerva Osteopathy 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. Minerva Osteopathy 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
Minerva Osteopathy 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. Minerva Osteopathy does not store
personal data outside the EEA.
10 – Your rights as a data subject
At any point whilst Minerva Osteopathy 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 Minerva Osteopathy 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 Minerva Osteopathy 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 (Minerva Osteopathy) 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 Minerva Osteopathy 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
Minerva Osteopathy 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 Minerva
Osteopathy is dissatisfied with the quality, further information may be sought
before personal data can be released.All
requests should be made to hazel@minervaosteopathy.co.uk or by phoning +44 (0) 1494 936800 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 Minerva Osteopathy 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:
Hazel Hanley
Telephone +44 (0) 1494 936800 or email: hazel@minervaosteopathy.co.uk