1 - Scope
This privacy notice (sometimes referred to as a privacy policy or privacy statement)
concerns personal data, which is defined as information concerning any living
person (a natural person who hereafter will be called the Data Subject) that is
not already in the public domain.
UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018
and the Privacy and Electronic Communications Regulations (PECR), seek to
protect and enhance the rights of UK data subjects. These rights cover the
safeguarding of personal data, protection against the unlawful processing of
personal data and its storage within the UK.
1- Your Practice Cathedral Road Clinic,
based at 242 Cathedral Road Cardiff CF119JG,
which hereafter for the purposes of this privacy notice will be referred
to as the Osteopaths, is pleased to provide the following information:
2 - Who we are
The Osteopaths diagnose and treat musculoskeletal conditions. Treatments are
carried out in accordance with the Institute of Osteopathy patient’s charter.
The practice may also provide other treatments,
about which our staff would be pleased to provide more details.
3 - Personal Data
a) For the purposes of providing treatment Osteopaths may require detailed medical
information. We will only collect what is relevant and necessary for your
treatment. When you visit our practice, we will make notes which may include
details concerning your health, medication, treatment and other issues
affecting your musculoskeletal conditions. This data is always held securely,
is not shared with anyone not involved in your treatment, although for data
storage purposes it may be handled by pre-vetted staff who have all signed an
integrity and confidentiality agreement. To be able to process your personal
data it is a condition of any treatment that you give your explicit consent to allow
Osteopaths to document and process your personal medical data. Contact details
provided by you such as telephone numbers, email addresses, postal addresses
may be used to remind you of future appointments, provide reports or other
information concerning your treatment.
b) For marketing purposes, the Osteopaths may also use the contact details provided
by you to respond to your enquiries including making telephone contact and emailing
information to you which the practice believes may be of interest to you.
c) In making initial contact with the practice you consent to Osteopaths maintaining
a marketing dialogue with you until you either opt out (which you can do at any
time) or we decide to desist in promoting our services. Osteopaths
may occasionally also act on behalf of its patients in the capacity of data
processor, when we may promote other practitioners based at our premises, who
may not be employed by us. Osteopaths do not broker your data and you can ask
to be removed from our marketing database by emailing or phoning the practice
using the contact details provided at the end of this privacy notice.
d) Some basic personal data may be collected about you from the marketing forms
and surveys you complete, from records of our correspondence and phone calls
and details of your visits to our website, including but not limited to,
personally identifying information like Internet Protocol (IP) addresses.
e) Osteopaths’ website uses cookies, which is a string of information that a
website stores on a visitor’s computer, and that the visitor’s browser provides
to the website each time the visitor returns. WordPress.org uses cookies to
help Osteopaths to identify and track visitors and their website access
preferences. Osteopaths’ website visitors who do not wish to have cookies
placed on their computers should set their browsers to refuse cookies before
using Osteopaths’ website.
f) Osteopaths will only collect the information needed so that it can provide you
with the services required.
4 - Legal basis for processing any personal data
To meet our contractual obligations obtained from explicit Patient Consent and legitimate
interest to respond to enquiries concerning the services provided.
5 - Legitimate interests pursued by Osteopaths
To promote treatments for patients with all types of musculoskeletal problems
including back pain and neck pain, tennis elbow, frozen shoulders, sciatica,
headaches, sports injuries, and other degenerative conditions.
6 - Consent
Through agreeing to this privacy notice you are consenting to Osteopaths processing
your personal data for the purposes outlined. You can withdraw consent at any
time by using the postal, email address or telephone number provided at the end
of this privacy notice.
7 - Disclosure
Osteopaths will keep your personal information safe and secure, only staff engaged in
providing your treatment will have access to your patient records, although our
administration team will have access to your contact details so that they can
make appointments and manage your account. Osteopaths will not disclose your
Personal Information unless compelled in order to meet legal obligations,
regulations or valid governmental requests. The practice may also enforce its
Terms and Conditions, including investigating potential violations of its Terms
and Conditions to detect, prevent or mitigate fraud or security or technical
issues; or to protect against imminent harm to the rights, property or safety
of its staff.
8 - Retention Policy
Osteopaths will process personal data during the duration of any treatment and will
continue to store only the personal data needed for eight years after the
contract has expired to meet any legal obligations. After eight years all
personal data will be deleted, unless basic information needs to be retained by
us to meet our future obligations to you, such as erasure details. Records
concerning minors who have received treatment will be retained until the child
has reached the age of 25.
9 - Data storage
All Data is held in the United Kingdom.
10 - Your rights as a data subject
any point whilst Osteopaths is in possession of, or processing your personal
data, all data subjects have the following rights:
· Right to information - you can ask for information about what data is being processed
and the rationale for such processing.
·
Right of access – you have the right to
request a copy of the information that we hold about you.
·
Right of rectification – you have a right to
correct data that we hold about you that is inaccurate or incomplete.
·
Right to be forgotten – in certain
circumstances you can ask for the data we hold about you to be erased from our
records.
·
Right to restriction of processing – where
certain conditions apply you have a right to restrict the processing.
·
Right of portability – you have the right to
have the data we hold about you transferred to another organisation.
·
Right to object – you have the right to object
to certain types of processing such as direct marketing.
·
Right to object to automated processing,
including profiling – you also have the right not to be subject to the legal
effects of automated processing or profiling.
In the event that Osteopaths refuses your request under rights of access, we will
provide you with a reason as to why, which you have the right to legally
challenge.
At your request Osteopaths can confirm what information it holds about you and how
it is processed.
11 - You can request the following information:
Identity and the contact details of the person or organisation (Osteopaths)
that has determined how and why to process your data.
.
Contact details of the data protection officer, where applicable.
.
The purpose of the processing as well as the legal basis for processing.
.
If the processing is based on the legitimate interests of Osteopaths
and information about these interests.
.
The categories of personal data collected, stored and processed.
.
Recipient(s) or categories of recipients that the data is/will be disclosed to.
.
How long the data will be stored.
.
Details of your rights to correct, erasure, restrict or object to such processing.
.
Information about your right to withdraw consent at any time.
.
How to lodge a complaint with the supervisory authority (ICO).
.
Whether the provision of personal data is a
statutory or contractual requirement, or a requirement necessary to enter into
a contract, as well as whether you are obliged to provide the personal data and
the possible consequences of failing to provide such data.
·
The source of personal data if it wasn’t collected directly from you.
·
Any details and information of automated
decision making, such as profiling, and any meaningful information about the
logic involved, as well as the significance and expected consequences of such
processing.
12 - To access what personal data is held,
identification will be required
Osteopaths will accept the following forms of ID when information on your personal data is
requested: a copy of your driving licence, passport, birth certificate and a utility bill not older than three months. A minimum of one piece of photographic ID listed above and a supporting document is required. If Osteopaths is dissatisfied with the quality, further information may be sought before personal data can be released.
All requests should be made on the contact form on the website or by phoning +44
(0) 2920235220 or writing to us at the address further below.
13 - Complaints
In the event that you wish to make a complaint about how your personal data is
being processed by Osteopaths you have the right to complain to us. If you do
not get a response within 30 days you can complain to the ICO.
The details for each of these contacts are:
Mark McWilliam
242 Cathedral Road Clinic Cardiff CF11 9JG
Telephone 02920235220 or email: clinic@cathedralroadclinic.co.uk
ICO
Wycliffe House, Water Lane, Wilmslow, SK9 5AF
Telephone+44 (0) 303 123 1113 or email: https://ico.org.uk/global/contact-us/email/