Version number: 001

Date: 24/5/18


Clinic patient privacy statement

The Chiropractic + Massage Clinic Ltd is aware of its obligations under the General Data Protection Regulation (GDPR) and is committed to protecting the privacy and security of your personal information. This privacy notice describes, in line with GDPR, how we collect and use personal data about you during and after your time as a patient of this clinic. It also sets out how we use that information, how long we keep it for and other relevant information about your data.

This notice applies to current and former patients.

Data controller details
The Clinic is a data controller, meaning that it determines the processes to be used when using your personal data. Our contact details are as follows:

Mark Griffin
Chiropractic + Massage Clinic Ltd
Bosq Lane
St Peter Port
Guernsey
GY1 2LP

01481 723724
mg@cmc.gg

 

Data protection principles
In relation to your personal data, we will comply with data protection law. This says that the personal information we hold about you must be:

  • processed fairly, lawfully and in a clear, transparent way
  • collected only for valid reasons that we find proper for the course of your time as a patient and not used in any way that is incompatible with those purposes only used in the way that we have told you about
  • accurate and up to date
  • kept only as long as is necessary for the purposes we outline
  • process it in a way that ensures it will not be used for anything that you are not aware of or have consented to (as appropriate), lost or destroyed
  • kept securely

 

Types of information we hold about you
Personal data or information means any information about an individual from which that person can be identified. It does not include data where the identity has been removed.
We hold many types of data about you, including:

  • your personal details including your name, address, date of birth, email address, phone numbers
  • banking or financial information – (If on a payment plan)
  • gender
  • marital status
  • personal medical or health information, including past medical history
  • information concerning examination and treatment at your first and subsequent visits
  • letters of referral to or from the clinic regarding your treatment with us.


How we collect your data
We collect data about you in a variety of ways and this will usually start when you make an enquiry to the clinic and continue when you attend your first and subsequent appointments. At this clinic, we keep paper and electronic records. Information we write down on paper may be transferred to our electronic system. We may receive information about you from your GP or other health care provider regarding your referral or, with your permission, additional information that will help us continue with your treatment. We may also hold the results of tests that you have undertaken and that are relevant to your treatment with the clinic.

Personal data is kept in the clinic both on paper and electronically, any and all date kept on paper is securely locked away in a filing cabinet of which the keys are stored in a further lockable box. We are working hard to make the clinic as paperless as possible and will be introducing eforms that will be filled in via an iPad and stored electronically. We store all electronic data on a clinic management system called Cliniko. Cliniko prides itself on being GDPR compliant and has many safeguards in place to protect personal data. All computers within the clinic are password protected, with a further two factor login when signing into Cliniko. Our network is protected by a firewall and we feel we have taken every precaution to comply with GDPR.


Why we process your data (How we will use information about you)
The law on data protection allows us to process your data for certain reasons only, these are classified as legitimate interests. Most commonly, we will use your personal information in the following circumstances:

  • in order for us to carry out our contract with you (your requesting treatment and our agreement to provide it constitutes a contract) which will include confirming appointments, informing you of changes to appointments or clinic arrangements, changes to facilities or services at the clinic.
  • in order to provide you with the best possible treatment by recording health and treatment information which would be in your best interest.
  • in order to carry out legally required duties such as those required by our government appointed regulators
  • where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests

We may use your personal information in these rare situations:

  • where we need to protect your or someone else’s interests
  • where it is needed in the public interest or for official purposes

Situations in which we will use your personal information
We need all the categories of information to primarily allow us to perform our contract of treatment with you and to enable us to comply with legal obligations.

If you do not provide your data to us
One of the reasons for processing your data is to allow us to carry out our duties in line with your contract of care with us. If you do not provide us with the data needed to do this, we will be unable to perform that care to ensure your best interests are being maintained. We may also be prevented from continuing with your treatment with us due to our legal obligations.

Change of purpose
We will only use your personal information for the purposes for which we collected it unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis, which allows us to do so.

Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Automated decision making
No decision will be made about you solely on the basis of automated decision making (where a decision is taken about you using an electronic system without human involvement), which has a significant impact on you.

Sharing your data
Your data will be shared with colleagues within the Clinic but only where it is necessary for them to undertake their duties. This includes, for example, other chiropractors or therapists working for, at or on behalf of the clinic, reception staff. Medical notes can only be accessed by Practitioners.

We may share your data with third parties in order to facilitate a referral to another healthcare practitioner, investigation or to keep your GP informed about your progress with treatment.

We may also share your data with third parties as part of a Clinic sale or restructure, or for other reasons to comply with a legal obligation upon us. We would always keep you informed of these situations.

Transferring information outside the EU
We may share your data with bodies outside of the European Economic Area should the need arise. It is likely that this situation would be to share information regarding your treatment or ongoing care with healthcare practitioners in these countries in accordance with your wishes. However, we would not transfer your data unless we were assured that the country in question had data security and protection laws of equivalence to those of the UK and the European Economic Area. We would put the measures in place to ensure that your data is transferred securely and that the bodies who receive the data process it in a way required by EU and UK data protection laws.

Data Security – Protecting your data
We have put in place measures to protect the security of your information against accidental loss or disclosure, alteration, unauthorised access, destruction or abuse. We have implemented processes to guard against such. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality. As mentioned we take data security very seriously and have taken many precautions to ensure that your data is safe. If you would like to know more detail about our protocols please contact our Data Officer, Mark Griffin at mg@cmc.gg.

Where we share your data with third parties, we provide written instructions to them to ensure that your data are held securely and in line with GDPR requirements. Third parties must implement appropriate technical and organisational measures to ensure the security of your data.

How long we keep your data for
In line with data protection principles, we only keep your data for as long as we need it for, which will be at least for the duration of your being a patient with us and we are legally required, by the Chiropractic regulator to keep this data for eight years after your time as a patient has ended. To determine any appropriate retention period for personal data beyond eight years we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means and the applicable legal requirements.

Once we no longer have a lawful use for retaining your information, we will dispose of it in a secure manner than maintains data security.

In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.

Your duty to inform us of changes
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your time as a patient with us.

Your rights in relation to your data
The law on data protection gives you certain rights in relation to the data we hold on you.

  • the right of access. You have the right to access the data that we hold on you. To do so, you should make a subject access request. Please contact our data protection officer, Mark Griffin at mg@cmc.gg and he will be able to assist.
  • the right for any inaccuracies to be corrected. If any data that we hold about you is incomplete or inaccurate, you can require us to correct it.
  • the right to be informed. This means that we must tell you how we use your data, and this is the purpose of this privacy notice. We also must inform you of any changes to how we use your data.
  • the right to have information deleted. If you would like us to stop processing your data, you have the right to ask us to delete it from our systems where you believe there is no reason for us to continue processing it.
  • the right to restrict the processing of the data. For example, if you believe the data we hold is incorrect, we will stop processing the data (whilst still holding it) until we have ensured that the data is correct.
  • the right to portability. You may request transfer the data that we hold on you for your own purposes.
  • If you want to access your data, review, verify or correct your data, request we erase your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact our data protection officer, Mark Griffin at mg@cmc.gg and he will be able to assist.

Fees
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee for a second or subsequent copy of information or if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

Right to withdraw consent
Where you have provided consent to the collection, processing and transfer of your data, you have the right to withdraw that consent at any time. There will be no consequences for withdrawing your consent. However, in some cases, we may continue to use the data where so permitted by having a legitimate legal reason for doing so.

To withdraw consent, contact our data protection officer, Mark Griffin at mg@cmc.gg and he will be able to assist.

Making a complaint
If you have any questions about this Privacy Notice or how we handle your information, please contact the Clinic’s Data Protection Officer, Mark Griffin at mg@cmc.gg.
You have the right to make a complaint at any time to the supervisory authority in Guernsey for data protection matters, the Information Commissioner’s Office (ICO).