Hannah Reade Acupuncture and CALM (Community Acupuncture Lancaster and Morecambe)
Purpose of privacy notice The processing of personal data is governed by the General Data Protection Regulation 2016/679 (the GDPR). This legislation will replace current data privacy law, giving more rights to you as an individual and more obligations to organisations holding your personal data. One of the rights is a right to be informed, which means we have to give you even more information than we do now about the way in which we use, share and store your personal information. This means that we will be publishing a new privacy notice so you can access this information, along with information about the increased rights you have in relation to the information we hold on you and the legal basis on which we are using it.
Who are we? Hannah Reade is the data controller. This means we decide how your personal data is processed and for what purposes.
Whose information does this privacy notice apply to? This privacy notice applies to information we collect from: • patients; • prospective patients; • former patients; • visitors to our website.
What is personal data? Personal data relates to a living individual who can be identified from that data. Identification can be by the information alone or in conjunction with any other information in the data controller’s possession or likely to come into such possession. Examples of personal data we may hold about you include your contact and appointment details. Special category data is a sub-category of personal data, in this case, concerning a persons health. Examples of special category data we may hold about you include your patient notes.
How do we process your personal data? We comply with our obligations under the GDPR by keeping personal data up to date; by storing and destroying it securely; by not collecting or retaining excessive amounts of data; by protecting personal data from loss, misuse, unauthorised access and disclosure and by ensuring that appropriate technical measures are in place to protect personal data. We use your personal data for the purposes set out below.
Complaint handling When we receive a complaint from a person we make up a file containing the details of the complaint. This normally contains the identity of the complainant and any other individuals involved in the complaint. We will only use the personal information we collect to process the complaint and to check on the level of service we provide. We usually have to disclose the complainant’s identity to whoever the complaint is about. If a complainant doesn’t want information identifying him or her to be disclosed, we will try to respect that. However, it may not be possible to handle a complaint on an anonymous basis. We may need to provide personal information collected and processed in relation to complaints to the British Acupuncture Council or our insurance company. We will keep personal information contained in complaint files in line with our retention policy. This means that information relating to a complaint will be retained for two years from closure. It will be retained in a secure environment and access to it will be restricted according to the ‘need to know’ principle. Similarly, where enquiries are submitted to us we will only use the information supplied to us to deal with the enquiry and any subsequent issues and to check on the level of service we provide.
Sharing your personal data Your personal data will be treated as strictly confidential, and will be shared: • with named third parties with your explicit consent; • with the relevant authority such as the police or a court, if necessary for compliance with a legal obligation to which we are subject e.g. a court order; • with your doctor or the police if necessary to protect yours or another person’s life; • with the police or a local authority for the purpose of safeguarding a children or vulnerable adults; or • with my regulatory body, the British Acupuncture Council, or my insurance company in the event of a complaint or insurance claim being brought against me; or • my solicitor in the event of any investigation or legal proceedings being brought against me. For further details about the situations when information about you might be shared please see the Information Commissioner’s website at https://ico.org.uk/for-the-public/personal-information/sharing-my-info/
How long do we keep your personal data? We keep your personal data for no longer than reasonably necessary. We keep patient records for a period of 7 years from the point at which you cease being a patient in accordance with the British Acupuncture Code of Professional Conduct https://www.acupuncture.org.uk/public-content/effective-practice/bacc-professional-codes.html We keep these records for the period of seven years for following reasons: Tax purposes - so that we can accuractly report our finanances to tax authorities on an annual basis and to ensure we can comply with an auditing activity. Secure potential evidence in the event of a criminal prosecution - in the event we are required to produce this information in the context of a criminal prosecution. Civil litigation - in the event that any litigation is brought against either myself, or action you may be take on a third party. Insurance claim or complaint to my regulatory body, the British Acupuncture Council - so that the complaints procedure has the necessary evidence to be concluded. In the the event that all employees of CALM or Hannah Reade Acupuncture become ill or die then an interim Data Protection Officer will be appointed to close the affairs of the business and to ensure that its continuing obligations under the GDPR are met and that all rights of the data subject are upheld for any period required by law. At any time you may request that changes are made to your contact details. Your rights and your personal data Unless subject to an exemption under the GDPR, you have certain rights with respect to your personal data as set out below. • The right to request a copy of your personal data which we hold about you. • The right to request that we correct any personal data if it is found to be inaccurate or out of date. • The right to request your personal data is erased where it is no longer necessary for us to retain such data. • The right to withdraw your consent to the processing at any time. This right does not apply where we are processing information using a lawful purpose other than consent. • The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), (where applicable) [This right only applies where the processing is based on consent or is necessary for the performance of a contract with you and in either case the we are processing the data by automated means]. • The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing. • The right to object to the processing of personal data, (where applicable) [This right only applies where processing is based on legitimate interests (or the performance of a task in the public interest/exercise of official authority); direct marketing and processing for the purposes of scientific/historical research and statistics]. • The right to be informed if your data is lost. We shall also inform the Information Commissioner’s Office in accordance with the time limits in the GDPR. • The right to lodge a complaint with the Information Commissioner’s Office. For further details about these rights please see the Information Commissioner’s website at https://ico.org.uk/for-the-public/is-my-information-being-handled-correctly/
Further processing If we wish to use your personal data for a new purpose, not covered by this Privacy Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions. Where and whenever necessary, we will seek your prior consent to the new processing.
Contact Details To exercise all relevant rights, queries or complaints please in the first instance you can contact our Data Protection Officer - Hannah Reade via email firstname.lastname@example.org You can contact the Information Commissioners Office on 0303 123 1113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire. SK9 5AF.
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