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 General Data Protection Regulation – ie the law):
1. We need to collect personal information about your health in order 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.
2. We have a “Legitimate Interest” in collecting that information, because without it we couldn’t do our job effectively and safely.
3. We also think that it is important that we can contact you in order to confirm your appointments with us or to update you on matters related to your chiropractic and massage and health care. This again constitutes “Legitimate Interest”, but this time it is your legitimate interest.
4. Provided we have your consent, we may occasionally send you general health information in the form of articles, advice or newsletters. This is done via MailChimp who are compliant with data privacy laws such as GDPR. You may withdraw this consent at any time, there will always be an unsubscribe click through button on any of our marketing emails or newsletters.
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 permanently 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 out of working hours.
- electronically (“in the cloud”), we use Cliniko for our patient records and note taking. 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, that are linked to a secure external hard drive that automatically backs up the data regularly and holds it in a secure cloud system. These are password-protected and the office(s) are locked 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 clinic software provider “Cliniko” who store and process patient files
- Your practitioner(s) in order that they can provide you with treatment
- If we need to refer you for an X-ray or MRI, we use a third party, without filing in a request form which has your personal information on including this wouldn’t be possible. The information required includes name, address, DOB and relevant medical history.
- If we need to write to your GP at any stage of your care, we require your consent. The letter will include your name, address, DOB and relevant medical history along with any recommendations for further imaging or testing. We may disclose your protected health information in an emergency or when we feel your safety is at risk.
- 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 bookkeeper who uses Xero accounting. Again, administrative staff will not have access to your medical notes, just your essential contact details.
- We also use MailChimp to coordinate our messages, so your name and email address may be saved on their server.
- From time to time, we may have to employ consultants ( e.g. IT support) 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 permanently erase your records.
- We want you to be absolutely 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:
- Controllers name: P5 Chiropractic and Health Ltd Email: email@example.com Phone number: 01892 543 878, Address: TWC Chiropractic Royal Victoria House 51-55 The Pantiles, Tunbridge Wells Kent TN2 5TE If you are not satisfied with our response, then you have the right to raise the matter with the Information Commissioner’s Office