Why we collect
your personal data and what we do with it.
In providing your
osteopathic healthcare and treatment, we will
ask for information about you and your health.
This privacy notice describes the type of
personal information we hold, why we hold it,
and what we do with it.
About us
We are The Active
Health Clinic.
Our main practice
contact address is 50-54 Wigmore Street, London
W1U 2AU
Information that
we hold
We only keep and
use information for specific reasons guided by
the EU General Data
Protection Regulation (GDPR) and the UK Data
Protection Act 2018. Below, we describe
the information we hold and why, and the lawful
basis for collecting and using it.
Contact Details
We hold personal
information about you including your name, date
of birth, insurance details if provided,
address, telephone number and email address.
This information allows us to fulfil our
contract with you to provide appointments. If
required, we may also use the information to
send you reminders and recall appointments as we
have a legitimate interest to ensure your
continuing care and to make you aware of our
services.
Medical Records
We hold
information about your health, including:
-
Clinical
records made by our practitioners and other
medical professionals involved in your care
and treatment
-
MRI scans,
X-rays, clinical photographs and reports
-
Medical
histories
-
Treatment
plans and consent
-
Notes of
conversations with you about your care
-
Dates of your
appointments
-
Details of any
complaints you have made and how these
complaints were dealt with
-
Correspondence
with you and other health professionals or
institutions regarding your health and care
We collect and use
this information to allow us to fulfil our
contract with you, to discuss your treatment
options and provide care that meets your needs.
We also use this information for the legitimate
interest of ensuring the quality of the
treatment we provide.
Financial
information
We hold
information about the fees we have charged, the
amounts you have paid and some payment details.
This information forms part of our contractual
obligation to you to provide osteopathic health
care and allows us to meet legal financial
requirements.
How we use your
information
When you supply
your personal details to this clinic they are
stored and processed for 4 reasons (the terms in
bold are the relevant terms used in the General
Data Protection Regulation - GDPR):
-
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.
-
We have a
“Legitimate Interest” in collecting that
information, because without it we could not
do our job effectively and safely.
-
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 medical care. This again constitutes
“Legitimate Interest”, but this time it is
your legitimate interest.
-
Provided you
have given us your explicit consent, we may
occasionally send you general clinic
information and marketing correspondence.
You may withdraw this consent at any time –
please just let us know by any convenient
method.
We may conduct
patient surveys to find out if you are happy
with the treatment you received for quality
control purposes.
Keeping your
information safe
We have a legal
obligation to retain your records for 8 years
after your most recent appointment (or age 25,
if this is longer).
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”). Access to this data is
password protected, and the passwords are
changed regularly.
-
On our office
computers which are password-protected and
backed up regularly.
Sharing
information
Only the following
people/agencies will have routine access to your
data:
-
Your
practitioner(s) in order that they can
provide you with treatment
-
Our support
staff, for example secretaries, in order
that they can assist your practitioner(s)
with referrals, correspondence, sending your
test requests or results (but they do not
have access to any other elements of your
medical records or sensitive personal
information)
-
Our reception
staff, because they may organise our
practitioners’ diaries and coordinate
appointments (but they do not have access to
your medical records or sensitive personal
information)
Your information
is normally used only by those working for the
clinic but there may be instances where we need
to share it in the context of your care – for
example, with:
-
Your general
practitioner
-
The hospital
or other health professionals caring for you
-
Medical
services to which we may refer you
-
Debt
collection agencies
-
Health
Insurance schemes of which you are a member
We will only
disclose your information on a need-to-know
basis and will limit any information that we
share to the strict minimum. We will give you
notice if we send your medical information to
another medical provider and we will give you
the details of that provider at that time.
From time to time,
we may have to employ external technical
consultants to perform tasks which might give
them access to your personal data (but not your
medical records). 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.
In certain
circumstances or if required by law, we may need
to disclose your information to a third party
not connected with your health care, including
HMRC or other law enforcement or government
agencies.
For information
regarding your rights in relation to the
Covid-19 pandemic and clarification about
confidential information and public health
please see:
https://www.nhsx.nhs.uk/covid-19-response/data-and-information-governance/information-governance/copi-notice-frequently-asked-questions/
and
https://ico.org.uk/global/data-protection-and-coronavirus-information-hub/data-protection-and-coronavirus/health-social-care-organisations-and-coronavirus-what-you-need-to-know/
Access to your
information and other rights
You have a right
to access the information that we hold about you
and to receive a copy. We do not usually charge
you for copies of your information; if we pass
on a charge, we will explain the reasons.
You can also
request us to:
-
Correct any
information that you believe is inaccurate
or incomplete. If we have disclosed that
information to a third party, we will let
them know about the change.
-
Erase some of
the information we hold. For legal reasons,
we may be unable to erase certain
information (for example, information about
your treatment). However, we can, if you ask
us to, delete some contact details and other
non-clinical information.
-
Stop using
your information – for example, sending you
information about our service. Even if you
have given us consent to send you marketing
information, you may withdraw that consent
at any time.
-
Stop using
information if you believe the information
is inaccurate or you believe we are using
your information illegally.
-
Supply your
information electronically to another
medical practitioner.
If we are relying
on your consent to use your personal information
for a particular purpose, you may withdraw your
consent at any time and we will stop using your
information.
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.
For any requests
or any concerns about how we use your
information, please contact our “Privacy
Manager”:
Claire
Cheetham - 020 7486 8141 mail@activehealthclinic.com
If you are not
satisfied with our response, then you have the
right to raise the matter with the Information
Commissioner’s Office (ico.org.uk).
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