This document refers to 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. The General Data Protection Regulation (GDPR) which is EU wide and far more extensive than its predecessor the Data Protection Act, along with the Privacy and Electronic Communications Regulations (PECR), seek to protect and enhance the rights of EU data subjects. These rights cover the safeguarding of personal data, protection against the unlawful processing of personal data and the unrestricted movement of personal data within the EU and its storage within the EEA. Your Practice, Bridgeham Clinic, based at 1 Oak Cottage, County Oak Way, Crawley, RH11 7ST, which hereafter for the purposes of this Privacy Notice will be referred to as the Clinic, is pleased to provide the following information:
1. Who we are
The Clinic’s practitioners diagnose and treat health conditions. Osteopathic treatments are carried out in accordance with the Institute of Osteopathy’s patient charter http://www.iosteopathy.org/osteopathy/the-patient-charter/. Other practitioners at the Clinic provide additional treatments, including Pilates/Garuda machine and mat, massage, acupuncture and foot health, about which our practitioners and staff will be pleased to provide more details.
2. Personal Data
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 the Clinic, Osteopaths and other Practitioners
To promote treatments for patients with all types of health problems indicated for osteopathic care and/or additional treatments provided at the Clinic by other practitioners.
Through agreeing to this Privacy Notice you are consenting to the Clinic and practitioners 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.
The Clinic will keep your personal information safe and secure. Only Practitioners 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. Practitioners will not disclose your Personal Information unless compelled to, in order to meet legal obligations, regulations or valid governmental requests. The Clinic 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
Practitioners 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 written data is held in the United Kingdom. Our computer system is hosted by Mindbody in the USA. Practitioners do not store personal data outside the EEA.
10. Your rights as a data subject
At any point whilst practitioners and the Clinic are in possession of, or processing your personal data, all data subjects have the following rights:
- 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 the Clinic or practitioner 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 the Clinic or practitioner can confirm what information it holds about you and how it is processed.
11. You can request the following information:
- The identity and contact details of the person or organisation (practitioners) 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 practitioners 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
The Clinic and practitioners will accept the following forms of identification (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 the Clinic or practitioners are dissatisfied with the quality, further information may be sought before personal data can be released. All requests should be made by email to firstname.lastname@example.org, or by phoning 01293 542245 and speaking to the Practice Manager, or writing to The Practice Manager at Bridgeham Clinic, 1 Oak Cottage, County Oak Way, Crawley, West Sussex, RH11 7ST. The name of your practitioner should be quoted in all correspondence.
How we collect or obtain personal information about you
We collect personal information when you provide it to us:
- when you fill in a form on our website
- when you contact us by phone, email or in writing
- when you use post or react to our social media channels
- when you order goods or services from us
Where permitted by law we may also receive information about you from third parties such as affiliates, business partners, credit and fraud checking services as well as third parties with whom we have had no prior contact.
How we collect anonymous information about your behaviour
We indirectly collect anonymous information about you to get a general idea of how our website is performing, this information is not linked directly to you but third party services outside of our control may use this to profile your activities and provide relevant advertising in other platforms. This may occur at any time while you are browsing our website.
Cookies are small packets of information stored on your device used to keep a record of your history while using a particular website. This could be used to tailor page content to your past behaviour, to keep hold of information that lets us know if you've logged in, or to let us know what items you've added to a shopping cart. The cookies under our control are only visible to you and to our website. While you are free to disable cookies on your browser, doing so may impact the functionality of this and other websites you visit and as such is not recommended.
Third Party Cookies
We use other services to help us to deliver our website, and they may also store cookies on your device to display personalised content or to gather statistics while you are visiting our website. We'll list those in detail and give a brief overview of why and how we use them below.
Information you submit to us on a contact form will be sent by email to our staff, and will remain stored on the website or within backups for a maximum of 60 days just in case the email doesn't get to us. If we intend to retain information for marketing purposes we’ll ask you first and give details on the form.
User submitted Comments & Reviews
You can submit comments on our content if you want to. Normal visitors will be able to read anything that you post, and the name under which you have submitted the comment. You may use a pseudonym if you prefer to remain anonymous. We may ask for your email address to verify but we will never make this public.
Visitors can subscribe to our newsletters and marketing material. We offer various newsletter signup forms on our site. In the case of forms which are purely for this purpose and clearly labelled as such, consent is assumed and a double opt-in email may be sent out for confirmation before you are officially subscribed to any lists. Please follow the instructions on any emails sent if you wish to unsubscribe or change your communication preferences.
Third-Party Services we may share data with
Third Party Analysis Tools
We use the following third party services to track and monitor visitor flows and behaviour.
Social Media Services
Some pages of our web site may connect with the following social media services. These may use third party cookies to connect with your own account to provide personalised content.
Email Communication Services
We use the following third party services to send email, so they will indirectly have access to a portion of your activity and some of your personal details. Once an email leaves systems we use directly, it may be routed through any number of others systems.
In the event that you wish to make a complaint about how your personal data is being processed by practitioners 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: Trevor and Jo Strutt Bridgeham Clinic, 1 Oak Cottage, County Oak Way, Crawley, West Sussex, RH11 7ST Telephone 01293 542245 or email: email@example.com ICO Wycliffe House, Water Lane, Wilmslow, SK9 5AF Telephone +44 (0) 303 123 1113 or email: https://ico.org.uk/global/contact-us/email/