(Why we collect your personal data and what we do with it)
When you supply your personal details to this clinic they are stored and processed for 4 reasons (the bits in bold are the relevant terms used in the Data Protection Act 2018, which includes the General Data Protection Regulation – i.e. the law):
- We need to collect personal information about your health to provide you with the best possible treatment. Your requesting treatment and our agreement to provide that care constitutes a contract. You can, of course, refuse to provide the information, but if you were to do that we would not be able to provide treatment.
- We have a “Legitimate Interest” in collecting that information, because without it we couldn’t do our job effectively and safely.
- We also think that it is important that we can contact you to confirm your appointments with us or to update you on matters related to your medical care. This again constitutes “Legitimate Interest”, but this time it is your legitimate interest.
- Provided we have your consent, we may occasionally send you general health information in the form of articles, advice or newsletters. You may withdraw this consent at any time – just let us know by any convenient method.
We have a legal obligation to retain your records for 8 years after your most recent appointment (or age 25, if this is longer), but after this period you can ask us to delete your records if you wish. Otherwise, we will retain your records indefinitely in order that we can provide you with the best possible care should you need to see us at some future date.
Your records are stored:
– on paper, in locked filing cabinets, and the offices are always locked and alarmed out of working hours. – electronically (“in the cloud”), using a specialist medical records service. This provider has given us their assurances that they are fully compliant with the General Data Protection Regulations. Access to this data is password protected, and the passwords are changed regularly. – on our office computers. These are password-protected, backed up regularly, and the offices are locked and alarmed out of working hours.
We will never share your data with anyone who does not need access without your written consent. Only the following people/agencies will have routine access to your data:
- The medical records service who store and process our files
- Your practitioner(s) in order that they can provide you with treatment
- Our reception staff, because they organise our practitioners’ diaries, and coordinate appointments and reminders (but they do not have access to your medical history or sensitive personal information)
- Other administrative staff, such as our finance team. Again, administrative staff will not have access to your medical notes, just your essential contact details.
- We also use InfusionSoft to coordinate our messages, so your name and email address may be saved on their server. We also use this platform for marketing purposes (on you opt-ing in for this service)
From time to time, we may have to employ consultants to perform tasks which might give them access to your personal data (but not your medical notes). We will ensure that they are fully aware that they must treat that information as confidential, and we will ensure that they sign a non-disclosure agreement.
You have the right to see what personal data of yours we hold, and you can also ask us to correct any factual errors. Provided the legal minimum period has elapsed, you can also ask us to erase your records.
We want you to be confident that we are treating your personal data responsibly, and that we are doing everything we can to make sure that the only people who can access that data have a genuine need to do so.
Of course, if you feel that we are mishandling your personal data in some way, you have the right to complain. Complaints need to be sent to what is referred to in the jargon as the “Data Controller”. Here are the details you need for that:
Unit B3, Fairacres Industrial Estate, Dedworth Road, Windsor, SL44LE
If you are not satisfied with our response, then you have the right to raise the matter with the Information Commissioner’s Office.
When ordering or registering on our site, as appropriate, you may be asked to enter your name, email address or other details to help you with your experience.
When do we collect information?
How do we use your information?
We may use the information we collect from you when you register, make a purchase, sign up for our newsletter, respond to a survey or marketing communication, surf the website, or use certain other site features in the following ways:
How do we protect visitor information?
We do not use vulnerability scanning and/or scanning to PCI standards.
Do we use ‘cookies’?
If you disable cookies off, some features will be disabled It won’t affect the users experience that make your site experience more efficient and some of our services will not function properly.
However, you can still place orders.
Third Party Disclosure
We do not sell, trade, or otherwise transfer to outside parties your personally identifiable information.
Third party links
Occasionally, at our discretion, we may include or offer third party products or services on our website. These third party sites have separate and independent privacy policies. We therefore have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these sites.
Google’s advertising requirements can be summed up by Google’s Advertising Principles. They are put in place to provide a positive experience for users. https://support.google.com/adwordspolicy/answer/1316548?hl=en
We have implemented the following:
- Remarketing with Google AdSense
- Remarketing with AdRoll
- Remarketing with Perfect Audience
- Remarketing with Other Companies
We along with third-party vendors, such as Google use first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) or other third-party identifiers together to compile data regarding user interactions with ad impressions, and other ad service functions as they relate to our website.
California Online Privacy Protection Act
How does our site handle do not track signals?
Does our site allow third party behavioral tracking?
COPPA (Children Online Privacy Protection Act)
When it comes to the collection of personal information from children under 13, the Children’s Online Privacy Protection Act (COPPA) puts parents in control. The Federal Trade Commission, the nation’s consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children’s privacy and safety online.
We do not specifically market to children under 13.
Fair Information Practices
The Fair Information Practices Principles form the backbone of privacy law in the United States and the concepts they include have played a significant role in the development of data protection laws around the globe. Understanding the Fair Information Practice Principles and how they should be implemented is critical to comply with the various privacy laws that protect personal information.
In order to be in line with Fair Information Practices we will take the following responsive action, should a data breach occur:
We also agree to the individual redress principle, which requires that individuals have a right to pursue legally enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that individuals have recourse to courts or a government agency to investigate and/or prosecute non-compliance by data processors.
CAN SPAM Act
The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.
We collect your email address in order to:
To be accordance with CANSPAM we agree to the following:
If at any time you would like to unsubscribe from receiving future emails, you can
By entering your contact information into the contact form, you are hereby giving us authorization to follow up with you via phone, or email regarding your inquiry. Furthermore, we enter patients into a subscribed follow-up system intended to educate them about our facility. You may opt-out of these emails at anytime by simply clicking the “unsubscribe” link on the footer of each email.
Definitions & Interpretation
In this Policy the following terms shall have the following meanings:
“Account” means an account required to access and/or use certain areas and features of Our Site;
“Cookie” means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site.
“Cookie Law” means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;
What is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
What are my rights?
Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:
• The right to access the personal data we hold about you.
• The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete.
• The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold.
• The right to restrict (i.e. prevent) the processing of your personal data.
• The right to object to us using your personal data for a particular purpose or purposes.
• The right to withdraw consent. This means that, if We are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time
• The right to data portability. This means that, if you have provided personal data to us directly, We are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases
• Rights relating to automated decision-making and profiling. We do not use your personal data in this way.
It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about Our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first.
What data do you collect and how?
Depending upon your use of Our Site, we may collect and hold some or all of the personal and non-personal data set out in the table below, using the methods also set out in the table. We do not collect any ‘special category’ or ‘sensitive’ personal data or personal data relating to children or data relating to criminal convictions and/or offences.
- Identity Information including name and title.
- Contact information including email address and telephone number(s).
- Technical information including IP address.
- Appointment details including date, time, appointment type and any associated message.
How do you use my personal data?
Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following table describes how we will use your personal data, and Our lawful bases for doing so:
- Supplying Our products and services to you. We collect your personal data in order to fulfil our contractual obligation to provide our products and services to you.
- Communicating with you. We use your personal data to communicate with you regarding our products and services.
- Supplying you with information by email or post that you have opted-in-to (you may opt-out at any time).
- With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email AND/OR telephone AND/OR text message AND/OR post with information, news, and offers on Our products and services. You will not be sent any unlawful marketing or spam. we will always work to fully protect your rights and comply with Our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.
- We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us.
- If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.
- In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights
Do you share my personal data?
We will not share any of your personal data with any third parties for any purposes, subject to the following exceptions.
Some of our services are provided by third-party organisations (eg appointment booking system and website hosting and management services). All of these third-party organisations are Data Processors under the GDPR and apply the same high privacy standards as we use ourselves.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if We are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
How can I control my personal data?
In addition to your rights under the Data Protection Legislation, when you submit personal data via Our Site, you may be given options to restrict Our use of your personal data. In particular, we aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in Our emails or at the point of providing your details).
You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
- Understand and save user’s preferences for future visits.
- Compile aggregate data about site traffic and site interactions in order to offer better site experiences and tools in the future. We may also use trusted third party services that track this information on our behalf.
- You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser (like Internet Explorer) settings. Each browser is a little different, so look at your browser’s Help menu to learn the correct way to modify your cookies.
- If you disable cookies off, some features will be disabled It won’t affect the users experience that make your site experience more efficient and some of our services will not function properly.
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change Our business in a way that affects personal data protection.