This Privacy Policy describes how and when we collect, use, and share information when you attend an appointment at our clinic, purchase a product from us, contact us, or otherwise use our services. This is to comply with the General Data Protection Regulations (GDPR) 2018.
Personal information we collect
1. Information we collect
To aid your treatment or as part of purchasing something from our business you will normally provide us with certain information, such as your name, email address, postal address, medical information and payment information. We will store your information on an electronic patient record and diary system called Practice Pal, which is fully password protected has triple surety protocols and resides on a secure server with multiple back-up systems. All medical, treatment and personal paper records taken are copied onto Practice-Pal and shredded within 48 hours as required by law.
Payment is never taken online, only through our own card machine. Each payment slip does not record all of your card number information only the last 4 digits and expiry date. Payment slips are discarded by shredding yearly once accounts are submitted to HMRC.
2. The legal bases we rely on to collect, use, and share personal information
Why we Need Your Information and How we Use It
We rely on a number of legal bases to collect, use, and share your information, including:
· where it is necessary for the purposes of the provision of health care as needed to provide our services, such as when we use your information to fulfil your podiatry assessment and treatment, or any other service we offer, such as Indian Head Massage, Ear Candling etc or to provide customer support;
· when you have provided your affirmative consent, which you may revoke at any time, such as by signing up for our mailing list;
if necessary to comply with a legal obligation or court order or in connection with a legal claim, such as retaining information about your purchases if required by tax law;
3. Marketing I undertake for my business
Marketing
From time to time we may wish to send you direct marketing material which may include product offers and newsletters. However Recalls in the form of texts or emails we do not consider as marketing and therefore will automatically send you reminders and confirmations for appointments once we have entered your information onto our system. If you wish to opt out of recalls or reminders please indicate to us at the time of the appointment.
If you are happy for us to do this please indicate in what forms you would like to receive this information:
Mail Email Text Phone No Marketing No Recalls/Reminders
4. The third parties with whom we share personal information
Information Sharing and Disclosure
Information about our patients/customers is important to our business. We share your personal information for very limited reasons and in limited circumstances, as follows:
· Medical professionals. With your consent we will share information with medical professionals such as your GP or consultant to allow continuity of care.
· Service providers. We engage certain trusted third parties to perform functions and provide services to our business, such as external reception services, Labs, Practice management, Orthotic manufacturers, and prescriptive remedy companies sent directly to you via the post. We will share your personal information with these third parties, but only to the extent necessary to perform these services.
· Business transfers. If we sell or merge our business, we may disclose your information as part of that transaction, only to the extent permitted by law and with your consent.
Compliance with laws. we may collect, use, retain, and share your information if we are legally
required to.
5. The length of time we keep personal information
Data Retention
We retain your personal information only for as long as necessary to provide you with our services and as described in our Privacy Policy. However, we may also be required to retain this information to comply with our legal and regulatory obligations, to resolve disputes, and to enforce our agreements. The retention of podiatry records is normally a minimum of 8 years, after the last appointment. For customers who are not patients but may have bought products from our business we will keep any data you may have provided for a minimum of 6 years in line with tax legislation.
6. If transferring personal information outside of Europe, how the transfer will be handled
We currently do not transfer any personal, medical information outside of the EU, all data is stored in the UK. For Example Practice-Pal uses-
https://www.rackspace.com/en-gb/gdpr. and is ISO certified https://www.rackspace.com/en-gb/compliance/iso.
7. Your rights regarding our use of your personal information and your contact details
You have a number of rights in relation to your personal information. While some of these rights apply generally, certain rights apply only in certain limited cases. We describe these rights below:
· Access. You have the right to access and receive a copy of the personal information we hold about you by contacting us using the contact information below. Please apply in writing or by email. However we require an admin fee of £35 and a period of up to 30 days from your application to us sending your said information.
· You may also have rights to change, restrict our use of, or delete your personal information. In the case of health records these are normally exempt from change and deletion requests.
· You can object to (i) our processing of some of your information based on our legitimate interests and (ii) receiving marketing messages from us after providing your express consent to receive them. In such cases, we will delete your personal information unless we have compelling and legitimate grounds to continue using that information or if it is needed for legal reasons.
If you wish to raise a concern about our use of your information (and without prejudice to any other rights you may have), you have the right to do so with the Information Commissioner www.ico.org.uk
How to Contact Me
For purposes of the GDPR, I, (Martin Vine), am the data controller of your personal information. If you have any questions or concerns, you may contact me ([email protected]). Alternately, you may mail me at:
Head2toe, The Venue, Elstree Way, Borehamwood, Herts WD6 4RB
020 8387 9910