(For the Osteopaths only)
(Why we collect your personal data and what we do with it)
When you supply your personal details to this clinic they are sorted and processed for 4 reasons (the bits in bold are the relevant terms used in the General Data Protection Regulation – i.e. 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. Otherwise, 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.
Your records are accessed from our office computers. These are password-protected and encrypted, backed up regularly, and the clinic/offices are locked and alarmed out of working hours. Your records are stored on servers which are based in the UK and maintained by JaneApp, who run our clinic software. Some data, such as our email system uses Microsoft 365 and for our marketing emails we use MailChimp. Both of these suppliers are based in the United States and both suppliers have signed the EU-US Privacy Shield agreement.
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:
• 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 (they have limited access to your medical history or sensitive personal information and are only able to see letters you have provided for us to scan in).
• Other administrative staff, such as our bookkeeper. Again, administrative staff will not have access to your medical notes, just your essential contact details.
• JaneApp, the software provider that allows us to store and process files necessary for our medical records and also provides our online booking facility.
• We also use Mailchimp to coordinate our messages, so your name and email address may be saved on their server.
• We use Microsoft Office 365 for our emails, if you have emailed us, your email address may be saved on their server.
• We carry out daily offsite backups. These sites are based within the UK and are fully encrypted.
From time to time, we may have to employ consultants to perform tasks which might give them access to your personal data. 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. Provided the legal minimum period has elapsed, you can also ask us to erase your records. To access what personal data is held, photo identification and utility bill may be required.
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:
140 South Street, Tarring, Worthing, BN14 7NB
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, SK9 5AF Telepohone +44 (0) 303 123 1113 or email: