Privacy Notice
Updated 24th January 2020
The practice aims to meet the requirements of the Data Protection Act 2018, the General Data Protection Regulation (GDPR], the guidelines on the Information Commissioner’s website as well as my professional guidelines and requirements.
The data controller is the Francis Scriven, the Information Governance Lead is Louise Hand who is also (in NHS practices) the Data Protection Officer.
This Privacy Notice is available on the practice website at www.angliaorthodontics.co.uk at reception, by email if you contact admin@angliaorthodontics.co.uk or by calling 01223 305526
You will be asked to provide personal information when joining the practice. The purpose of processing your personal data is to provide you with optimum orthodontic health care and prevention.
The categories and examples of data I process are:
Personal data for the provision of orthodontic health care
Personal data for the purposes of providing treatment plans, recall appointments, reminders or estimates
Personal data such as details of family members for the provision of health care to children or for emergency contact details
Personal data for the purposes of employed and self-employed team members employment and engagement respectively
Personal data for the purposes of [direct mail/email/text/other] to inform you of important announcements or about new treatments or services
Personal data - IP addresses so that I can understand my patients better and inform my marketing approach as well as improve the web site experience
Special category data including health records for the purposes of the delivery of health care and meeting my legal obligations
Special category data including health records
Special category data to meet the requirements of the Equality Act 2010
Special category data details of criminal record checks for employees and contracted team members
I minimise the data that I keep, and do not keep it for longer than necessary.
I never pass your personal details to a third party unless I have a contract for them to process data on my behalf and will otherwise keep it confidential. If I intend to refer a patient to another practitioner or to secondary care such as a hospital I will gain the individual’s permission before the referral is made and the personal data is shared. Your data will be shared with the NHS in England, if you are having NHS treatment.
Personal data is stored in the EU whether in digital or hard copy format
Personal data is stored in the US in digital format when the data storage company is certified with the EU-US Privacy Shield
Personal data is obtained when a patient joins the practice, when a patient is referred to the practice and when a patient subscribes to an email list or when a patient contacts us wishing more information on my practice and its treatments.
For full details or where your data is stored, please ask to see Information Governance Procedures (M 217C).
I have established the following lawful bases for processing your data:
My lawful bases for processing personal data:
Public tasks
The legitimate interests of the dental practice
Processing is necessary for the performance of a contract with the data subject or to take steps to enter into a contract
Consent of the data subject
To comply with my legal obligations
Other
My lawful bases for processing special category data:
Processing is necessary for health care purposes
Processing necessary for identifying or keeping under review the existence or absence of equality of opportunity or treatment between groups of people with the view to enabling such equality to be promoted or maintained
I obtain consent of the data subject to process criminal record checks
Substantial public interest
Employment and social security
The reasons I process the data include:
To maintain your contemporaneous clinical records
To provide you with dental treatment, prevention and oral health advice
To carry out financial transactions with you
To manage your NHS orthodontic treatment
To send your personal data to the General Dental Council or other authority as required by law
To communicate with you as and when required including appointment reminders, treatment plans, estimates and other communications about your treatment or the practice
To communicate with your next of kin in an emergency
If a parent or carer to communicate with you about the person you parent or care for
To refer you to other dentists or doctors and health professionals as required
To obtain criminal record disclosures for team members
For debt recovery
To continually improve the care and service you receive from us
The personal data I process includes:
Your name, address, gender, date of birth, NHS number, medical history, dental history, family medical history, family contact details, marital status financial details for processing payment, your doctor’s details and details of treatment at the practice. I may process more sensitive special category data including ethnicity, race, religion, or sexual orientation so that I can meet my obligations under the Equality Act 2010, or for example to modify treatment to suit your religion and to meet NHS or HSC obligations.
The retention period for special data in patient records is a minimum of 10 years and may be longer for complex records or to meet my legal requirements. The retention period for staff records is 6 years. The retention periods for other personal data is 2 years after it was last processed. Details of retention periods are available in the Record Retention (M 215) procedure available from the practice.
I obtain your personal details when you enquire about my care and service, when you join the practice, when you subscribe to my newsletter or register online, when you complete a registration or medical history form and when another practitioner refers you for treatment at my practice. Occasionally patients are referred to us from other official sources such as NHS clinics or hospitals.
You have the following personal data rights:
The right to be informed about the collection and use of your personal data
The right of access – to have a free copy of your data that I have
The right to rectification - to correct the data I have if it is inaccurate or incomplete
The right to deletion of your personal data (clinical records must be retained for a certain time period)
The right to restrict processing of your personal data
The right to data portability – to have your data transferred to someone else
The right to object to the processing of your personal data.
Rights in relation to automated decision making and profiling
Further details of these rights can be seen in my Information Governance Procedures (M 217C) or at the Information Commissioner’s website. Here are some practical examples of your rights:
If you are a patient of the practice you have the right to withdraw consent for important notifications, newsletters, surveys or marketing. You can inform us to correct errors in your personal details or withdraw consent from communication methods such as telephone, email or text. You have the right to obtain a free copy of your patient records within one month.
If you are not a patient of the practice you have the right to withdraw consent for processing personal data, to have a free copy of it within one month, to correct errors in it or to ask us to delete it. You can also withdraw consent from communication methods such as telephone, email or text.
I have carried out a Privacy Impact Assessment (M 217Q) and you can request a copy from the details below. The details of how I ensure security of personal data is in my Security Risk Assessment (M 217M) and Information Governance Procedures (M 217C).
Comments, suggestions and complaints
Please contact the Louise Hand at the practice for a comment, suggestion or a complaint about your data processing at admin@angliaorthodontics.co.uk, or 01223 305526 or by writing to or visiting the practice at Lammas Field Pavillion, Driftway, Cambridge, Cambridgeshire, CB3 9PA. I take complaints very seriously.
If you are unhappy with my response or if you need any advice you should contact the Information Commissioner’s Office (ICO). Their telephone number is 0303 123 1113, you can also chat online with an advisor. The ICO can investigate your claim and take action against anyone who’s misused personal data. You can also visit their website for information on how to make a data protection complaint.
Related practice procedures
You can also use these contact details to request copies of the following practice policies or procedures:
Data Protection and Information Security Policy (M 233-DPT), Consent Policy (M 233-CNS)
Privacy Impact Assessment (M 217Q), Information Governance Procedures (M 217C), Record Retention (M 215)
If you have an enquiry or a request please contact the Information Governance Lead,
Anglia Orthodontics,
Lammas Field Pavillion, Driftway, Cambridge, Cambridgeshire, CB3 9PA,
Email: admin@angliaorthodontics.co.uk,
Phone: 01223 305526
Thank You.
Data Opt-Out Policy (England)
How the NHS and care services use your information
Anglia Orthodontics is one of many organisations working in the health and care system to improve care for patients and the public. Whenever you use a health or care service, such as attending Accident & Emergency or using Community Care services, important information about you is collected in a patient record for that service. Collecting this information helps to ensure you get the best possible care and treatment. The information collected about you when you use these services can also be used and provided to other organisations for purposes beyond your individual care, for instance to help with:
Improving the quality and standards of care provided
Research into the development of new treatments
Preventing illness and diseases
Monitoring safety
Planning services
This may only take place when there is a clear legal basis to use this information. All these uses help to provide better health and care for you, your family and future generations. Confidential patient information about your health and care is only used like this where allowed by law.
Most of the time, anonymised data is used for research and planning so that you cannot be identified in which case your confidential patient information isn’t needed.
You have a choice about whether you want your confidential patient information to be used in this way. If you are happy with this use of information you do not need to do anything. If you do choose to opt out your confidential patient information will still be used to support your individual care. To find out more or to register your choice to opt out, please visit www.nhs.uk/your-nhs-data-matters. On this web page you will:
See what is meant by confidential patient information
Find examples of when confidential patient information is used for individual care and examples of when it is used for purposes beyond individual care
Find out more about the benefits of sharing data
Understand more about who uses the data
Find out how your data is protected
Be able to access the system to view, set or change your opt-out setting
Find the contact telephone number if you want to know any more or to set/change your opt-out by phone
See the situations where the opt-out will not apply
You can also find out more about how patient information is used at:
https://www.hra.nhs.uk/information-about-patients/ (which covers health and care research); and https://understandingpatientdata.org.uk/what-you-need-know (which covers how and why patient information is used, the safeguards and how decisions are made)
You can change your mind about your choice at any time.