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(Why we collect your personal data and what we do with it)
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 (name, address, contact phone numbers, email addresses, date of birth, GP etc) and 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. Appointment reminders will very often be in the form of text messages.
4. Provided we have your consent, we may occasionally send you general health information in the form of articles, advice, newsletters and at certain times of the year, birthday and Christmas cards. If you were on our system before 25th May 2018, we will continue to contact you legitimately under “soft opt-in” because a relationship already exists. You may withdraw this consent at any time – just let us know by any convenient method by contacting the “Data Controller”.
We have a legal obligation to retain your records for 8 years after your most recent appointment (or age 25 if under 18 at your last appointment, if this is longer), but after this period we are able to delete both your personal and medical data. You are also able to request us to delete your data at this point.
Your records are stored on paper, in locked filing cabinets, and the offices are always locked and alarmed out of working hours. They are also stored 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:
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. 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.
You have the right to see what personal data of yours we hold (this is usually without charge), and you can also ask us to correct any factual errors. If paper or digital copies are required, the charge for providing copies will not exceed £50 (but is usually significantly less). Provided the legal minimum period has elapsed, you can also ask us to erase your records. For any of these circumstances, contact the “Data Controller” via the details below.
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:
Complete Health Clinic
27 Melbourne Terrace
If you are not satisfied with our response, then you have the right to raise the matter with the Information Commissioner’s Office.