Privacy Policy

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 Splose, which uses AWS servers, please see additional information regarding Splose below.

Payment is not currently taken online, but we will be in the near future and update this policy in due course. Payments are currently taken using our Mobile payment system, invoices and receipts are currently sent via email.

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 this Privacy Policy describes how and when we collect, use, and share information when you attend an appointment at my 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.‍

• When you have provided your affirmative consent, which you may revoke at any time, such as by signing up for my 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 my 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 my 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, and Data protection

Data residency

For our UK users, your data is stored in the UK. For any international customers, Splose plan to invest in cloud storage in the EU, US and Canada.

‍‍Data is encrypted via SSL in transit and encrypted at rest using industry-standard AES-256 encryption.

‍Data backups

Splose create daily backups of your data, encrypt it and store it securely off-site. All data is stored redundantly at multiple AWS data centres to ensure availability.

Physical security

In addition to Splose’s internal security testing, They employ third-party firms to conduct vulnerability assessments. Results are prioritised, triaged, and remediated by their development team.

Password protection & 2FA

All users are required to create a strong password to log into Splose.  We use two-factor authentication which provides an extra layer of security.

Splose is our current Practice Management system.

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 me using the contact information below. Please apply in writing or by email. However we require an admin fee of £50 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 my 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 (martin@head2toeuk.com). Alternatively, you may mail me in writing to:

Head2toe, The Venue, Elstree Way, Borehamwood, Herts WD6 4RB

020 8387 9910

https://head2toeuk.com