OXFORD CENTRAL CHIROPRACTIC CLINIC LIMITED PATIENT PRIVACY POLICY INTRODUCTION
Welcome to the Oxford Central Chiropractic Clinic’s privacy notice. The Central Chiropractic Clinic respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you become are a patient of this clinic (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
1. IMPORTANT INFORMATION AND WHO WE ARE
Purpose of this privacy notice
This privacy notice aims to give you information on how the Central Chiropractic Clinic collects and processes your personal data during and after your time as a patient.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
Controller
The Central Chiropractic Clinic is the controller and responsible for your personal data (collectively referred to as “The Central Chiropracttic Clinic ", "we", "us" or "our" in this privacy notice).
The Central Chiropractic Clinic operates the website: www.oxfordchiropractic.co.uk
We have appointed a Data Privacy Manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the Data Privacy Manager using the details set out below.
Contact details
Name: Central Chiropractic Clinic
Name or title of Data Privacy Manager: Alan Shanks
Email address:
Telephone number 01865204246
Complaints
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Changes to the privacy notice and your duty to inform us of changes
This version was last updated in May 2018 and historic versions can be obtained by contacting us.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
2. THE DATA WE COLLECT ABOUT YOU
Personal data, or personal 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 (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows;
- Identity Data includes title, first name, last name, date of birth and gender.
- Contact Data includes email address, home address, billing address and telephone numbers.
- Special Category Data includes information about your health, genetics, sex life, sexual orientation, race, ethnic origin and religion.
- Financial Data includes bank account and payment card details
- Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
3. HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity, Contact, Special Category and Financial Data when you become a patient.
Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
- Referrers: who may provide us with Special Category data to facilitate your treatment with us.
- Insurance Companies.
- Solicitors.
4. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
1. Where we need to perform the contract we are about to enter into or have entered into with you.
- Performance of contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
2. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests.
3. Where we need to comply with a legal or regulatory obligation.
- Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Purposes for which we will use your personal data
1. Performance of our contract with you
- To register you as a new patient or take steps to register you as a new patient.
- To comply with our obligations under our contract, namely to provide you with the necessary treatment.
2. Legitimate interests
We rely on the legitimate interest basis to process your data in the following circumstances:
- To collect and recover money owed to us.
3. Legal or regulatory obligation
- We also rely on the legal or regulatory obligation ground to process your data in some circumstances. This means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
- Condition under which we process your special category data
To process your special category we rely on the contractual ground and also the special condition which allows health professionals to process the data for the purposes of preventative or occupational medicine, and the provisions of health care treatment. - Please contact us if you would like more details about the specific legal ground we are relying on to process your personal data.
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. If you would like to receive marketing from us we ask for your express consent. Please refer to our Website and Marketing Privacy Notice for more details.
Change of purpose
We will only use your personal data 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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data 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 data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below for the purposes set out in paragraph 4 above.
External Third Parties:
- Professional healthcare practitioners including to facilitate a referral, to keep your GP informed.
- Service providers based in UK who provide IT and system administration services.
- Professional advisers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances.
Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
If you have read and understood this new legislation, we would kindly ask that you complete a new GDPR form at reception on your next visit if you have not already done so.