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Privacy Notice

 

Sylvia Gulbenkian BVetMed MRCVS LicAc MBAcC DipPaed

Acupuncturist

 

Purpose of privacy notice

 

The processing of personal data is governed by the General Data Protection Regulation 2016/679 (the GDPR). This legislation will replace current data privacy law, giving more rights to you as an individual and more obligations to organisations holding your personal data.

One of the rights is a right to be informed, which means I have to give you even more information than I do now about the way in which I use, share and store your personal information.

This means that I will be publishing a new privacy notice so you can access this information, along with information about the increased rights you have in relation to the information I hold on you and the legal basis on which I am using it.

This new privacy notice comes into effect and will be published on my website on 25 May 2018. 

 

I, Sylvia Gulbenkian, am the data controller. This means I decide how your personal data is processed and for what purposes.

 

 

Whose information does this privacy notice apply to?

This privacy notice applies to information we collect from:

·   patients;

·   prospective patients;

·   former patients

 

What is personal data?

Personal data relates to a living individual who can be identified from that data. Identification can be by the information alone or in conjunction with any other information in the data controller’s possession or likely to come into such possession. Examples of personal data I may hold about you include your contact and appointment details.

 

Special category data is a sub-category of personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation. Examples of special category data I may hold about you include your patient notes.

 

How do I process your personal data?

I comply with my obligations under the GDPR by keeping personal data up to date; by storing and destroying it securely; by not collecting or retaining excessive amounts of data; by protecting personal data from loss, misuse, unauthorised access and disclosure and by ensuring that appropriate technical measures are in place to protect personal data. I use your personal data for the purposes set out below.

 

The following apply to my patients, former patients, prospective patients and visitors to my clinic:

 

  1. I use your name, address, telephone number and email address to make and rearrange appointments. This information is mostly in paper form only, unless you have sent it to me electronically yourself. I am unable to send or receive encrypted emails so you should be aware that any emails I send or receive may not be protected in transit. I will also monitor any emails sent to me, including file attachments, for viruses or malicious software. Please be aware that you have a responsibility to ensure that any email you send me is within the bounds of the law. With your permission, I will store your telephone number on my mobile telephone, allowing me to send out text reminders for appointments; your full name is not listed on the mobile, so you cannot be identified by a third party.  

  2. Some patients and prospective patients tell me about their medical conditions and medication by email. I am unable to send or receive encrypted emails so you should be aware that any emails I send or receive may not be protected in transit. I will also monitor any emails sent to me, including file attachments, for viruses or malicious software. Please be aware that you have a responsibility to ensure that any email you send me is within the bounds of the law.

  3. I keep a permanent attendance register which records all appointments for patients attending my clinic to keep a record of when you were treated for tax purposes and to secure potential evidence in the event of a criminal prosecution, civil litigation, insurance claim or complaint to my regulatory body, the British Acupuncture Council. This is in paper form only.

  4. I may use your date of birth to help identify patients with the same name to avoid mistakes being made as to safe and appropriate treatment, for identification purposes if referring a patient to another health practitioner, and for identification purposes if writing to a registered medical practitioner so that they correctly identify the patient.

  5. I use your presenting complaint and symptoms reported by you for the purposes of making a full traditional diagnosis, formulating treatment strategy and treatment planning. This is recorded and stored in paper form only.

  6. I use any relevant medical and family history you have told me for making a full traditional diagnosis, formulating treatment strategy and treatment planning. Again, this is recorded and stored in paper form only.

  7. I record your GP’s name and address in the event that I need to contact your GP, including in an emergency, and because it is a mandatory requirement in the British Acupuncture Code of Professional Conduct.

  8. I use our clinical findings about your health and wellbeing for making a full traditional diagnosis, and formulating treatment strategy and treatment planning. Again, this is recorded and stored in paper form only.

  9. I keep a record, and refer to that record, of any treatment given and details of progress of your case, including reviews of treatment planning to enable us to: review the full traditional diagnosis, treatment strategy and planning; and to secure evidence in the event of criminal proceedings, civil litigation, an insurance claim or complaint. Again, this is recorded and stored in paper form only.

  10. I record and use any information and advice that I have given, especially when referring patients to any other health professional, to help you to receive the most appropriate treatment and to secure evidence in the event of criminal proceedings, civil litigation, an insurance claim or complaint. Again, this is recorded and stored in paper form only.

  11. I record any decisions made in conjunction with you to help you to receive the most appropriate treatment and to secure evidence in the event of criminal proceedings, civil litigation, an insurance claim or complaint. Again, this is recorded and stored in paper form only.

  12. I keep accident records for any patients or visitors who are involved in accidents at my clinic in accordance with UK Health and Safety legislation including the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations (RIDDOR) to comply with the law and to secure evidence in the event of criminal proceedings, civil litigation, an insurance claim or complaint. 

  13. In the event of an adverse incident occurring to any of my patients, I report the matter to the British Acupuncture Council and the our insurance company to enable the insurance company to deal with any potential claims and to help the British Acupuncture Council to develop its safe practice guidelines, as well as providing research data and information for the BAcC’s insurers and other interested parties.

  14. All paper notes are stored in a locked filing cabinet.

 

 

 

Sharing your personal data

Your personal data will be treated as strictly confidential, and will be shared:

 

·   with named third parties with your explicit consent (e.g. an agreed referral to another practitioner);

·   with the relevant authority such as the police or a court, if necessary for compliance with a legal obligation to which I am subject e.g. a court order;

·   with your doctor or the police if necessary to protect yours or another person’s life;

·   with the police or a local authority for the purpose of safeguarding a child or vulnerable adult; or

·   with my regulatory body, the British Acupuncture Council, or my insurance company in the event of a complaint or insurance claim being brought against me; or

·   my solicitor in the event of any investigation or legal proceedings being brought against me.

 

For further details about the situations when information about you might be shared please see the Information Commissioner’s website at https://ico.org.uk/for-the-public/personal-information/sharing-my-info/

 

How long do I keep your personal data?

I keep your personal data for no longer than reasonably necessary.

I keep patient records for a period of 7 years in accordance with the British Acupuncture Code of Professional Conduct https://www.acupuncture.org.uk/public-content/effective-practice/bacc-professional-codes.html

 

 

Your rights and your personal data

Unless subject to an exemption under the GDPR, you have certain rights with respect to your personal data as set out below.

 

·   The right to request a copy of your personal data which I hold about you.

·   The right to request that I correct any personal data if it is found to be inaccurate or out of date.

·   The right to request your personal data is erased where it is no longer necessary for me to retain such data.

·   The right to withdraw your consent to the processing at any time. This right does not apply where I am processing information using a lawful purpose other than consent. 

·  ·   The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request that a restriction is placed on further processing.

·   The right to object to the processing of personal data, (where applicable) [This right only applies where processing is based on legitimate interests (or the performance of a task in the public interest/exercise of official authority); and processing for the purposes of scientific/historical research and statistics].

·   The right to be informed if your data is lost. I shall also inform the Information Commissioner’s Office in accordance with the time limits in the GDPR.

·   The right to lodge a complaint with the Information Commissioner’s Office.

 

For further details about these rights please see the Information Commissioner’s website at https://ico.org.uk/for-the-public/is-my-information-being-handled-correctly/

 

 

Further processing

If I wish to use your personal data for a new purpose, not covered by this Privacy Notice, then I will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions. Where and whenever necessary, I will seek your prior consent to the new processing.

 

Contact Details

To exercise all relevant rights, queries of complaints please in the first instance contact me at Billingshurst Osteopaths, 74 High Street, Billingshurst. West Sussex. RH14 9QS.

Email: sylvacu@hotmail.com. Phone: 07810 357075.

 

You can contact the Information Commissioners Office on 0303 123 1113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire. SK9 5AF.

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