PRIVACY POLICY
In accordance with the General Data Protection Regulation (GDPR), we have implemented this privacy notice to inform you, our clients, of the types of data we process about you. We also include within this notice the reasons for processing your data, the lawful basis that permits us to process it, how long we keep your data for and your rights regarding your data. This notice applies to any data subjects / clients.
A) DATA PROTECTION PRINCIPLES
Under GDPR, all personal data obtained and held by us must be processed according to a set of core principles. In accordance with these principles, we will ensure that: a) processing is fair, lawful and transparent b) data is collected for specific, explicit, and legitimate purposes c) data collected is adequate, relevant and limited to what is necessary for the purposes of processing d) data is kept accurate and up to date. Data which is found to be inaccurate will be rectified or erased without delay e) data is not kept for longer than is necessary for its given purpose f) data is processed in a manner that ensures appropriate security of personal data including protection against unauthorised or unlawful processing, accidental loss, destruction or damage by using appropriate technical or organisation measures g) we comply with the relevant GDPR procedures for international transferring of personal data.
B) TYPES OF DATA HELD
We keep several categories of personal data on our clients / data subjects in order to carry out effective and efficient processes. We keep this data in our software database relating to each client / data subject and we also hold the data within all Debbie Thomas Ltd computer portals which are relevant to your treatment.
Specifically, we hold the following types of data, as appropriate to your status: a) personal details such as name, address, phone numbers b) emergency contact details of a family member or friend c) your photograph d) your gender e) medical information f) CCTV footage.
C) COLLECTING YOUR DATA
You provide several pieces of data to us directly on each appointment that you attend including consultations.
Personal data is kept in our software database, in your client profile that is set up when you make your first booking, including a consultation. If you are aged 16 or under, please get your parent/guardian’s permission before you provide any personal information to us. Users of this nature and without this consent are not allowed to provide us with personal information.
D) LAWFUL BASIS FOR PROCESSING
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The law on data protection allows us to process your data for certain reasons only. In the main, we process your data in order to comply with a legal requirement or in order to effectively manage your treatment plans with the clinic.
The information below categorises the types of data processing, appropriate to your status, we undertake and the lawful basis we rely on.
Activity requiring your data/Lawful basis
Making reasonable adjustments for disabled data subjects/Legal obligation
Maintaining comprehensive up to date personal records about you to ensure, amongst other things, effective correspondence can be achieved and appropriate contact points in the event of an emergency are maintained/Our legitimate interests.
Gaining expert medical opinion when making decisions about your treatment plan, if needed/Our legitimate interests
Dealing with legal claims made against us/Our legitimate interests.
Preventing fraud/Our legitimate interests
Ensuring our administrative and IT systems are secure and robust against unauthorised access/ Our legitimate interests.
E) SPECIAL CATEGORIES OF DATA
Special categories of data are data relating to your: a) health.
We carry out processing activities using special category data:
a) to determine reasonable adjustments that may be needed.
Most commonly, we will process special categories of data when the following applies:
a) you have given explicit consent to the processing
b) we must process the data in order to carry out our legal obligations
c) we must process data for reasons of substantial public interest
d) you have already made the data public.
F) FAILURE TO PROVIDE DATA
Your failure to provide us with data may mean that we are unable to fulfil our requirements for entering into a contract with you, this contract enables us to proceed with treatments.
G) PROTECTING YOUR DATA
We are aware of the requirement to ensure your data is protected against accidental loss or disclosure, destruction and abuse. We have implemented processes to guard against such.
H) RETENTION PERIODS
We only keep your data for as long as we need it for, which will be at least for the duration of your time with us a client, with us though in most/all cases we will keep your data as long as necessary and potentially after you no longer visit the clinic, in order that should you return as a client in the future, we have a history of your treatments. Some data retention periods are set by the law. Our retention periods are: Retention periods can vary depending on why we need your data, as set out below:
I) AUTOMATED DECISION MAKING
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Automated decision making means making decision about you using no human involvement e.g. using computerised filtering equipment. 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.
J) CLIENT / DATA SUBJECT RIGHTS
You have the following rights in relation to the personal data we hold on you:
a) the right to be informed about the data we hold on you and what we do with it;
b) the right of access to the data we hold on you. More information on this can be found in our separate policy on Subject Access Requests;
c) the right for any inaccuracies in the data we hold on you, however they come to light, to be corrected. This is also known as ‘rectification’;
d) the right to have data deleted in certain circumstances. This is also known as ‘erasure’;
e) the right to restrict the processing of the data;
f) the right to transfer the data we hold on you to another party. This is also known as ‘portability’; g) the right to object to the inclusion of any information;
h) the right to regulate any automated decision-making and profiling of personal data.
K) CONSENT
Where you have provided consent to our use of your data, you also have the right to withdraw that consent at any time. This means that we will stop processing your data.
L) MAKING A COMPLAINT
If you think your data subject rights have been breached, you are able to raise a complaint with the Information Commissioner (ICO).
You can contact the ICO at Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF or by telephone on 0303 123 1113 (local rate) or 01625 545 745.
M) DATA PROTECTION COMPLIANCE
Our Data Protection Officer is: Jo Kaleta, Operations Director 0207118 9000 / Debbie Thomas Ltd, 25 Walton Street, London SW3 2HU.