Privacy Notice for Charminster House Dental Practice
Introduction:
Charminster House Dental Practice takes managing personal data very seriously and acts in accordance with the Data Protection Act 2018 as well as the General Data Protection Regulations.
This Privacy Notice is available on the practice website footer at https://charminsterdental.co.uk.
A copy can be requested from our reception team in person, via the telephone on 01202 292 030, via the contact us form on the website at https://charminsterdental.co.uk/contact-us, by emailing reception@charminsterdental.co.uk, or by writing to Charminster House Dental Practice, 65 Wellington Road, Bournemouth, Dorset, BH8 8JL.
Data Controller:
Charminster House Dental Practice of 65 Wellington Road, Bournemouth, Dorset, BH8 8JL is the “Data Controller”.
Purpose of Processing:
The Data Controller processes personal data for the purpose of:
- The provision of dental care to patients
- The provision of managing practice personnel (nurses, receptionists, practice managers, associates, hygienists, third party contractors)
- The provision of dental care to patients on referral from other healthcare providers
- The provision of managing patient referrals to and from other healthcare providers
- The provision and management of Continuing Professional Development (CPD) courses to healthcare professionals via Charminster House Seminars
- The management of patient appointments
- IP addresses so that we can understand our patients better and inform our marketing approach, improve the web site experience and gain feedback to improve our service
- Communicating via newsletters to existing referring healthcare providers, previous attendees on Charminster House Seminars CPD courses and existing patients of the practice
- Marketing to existing referring healthcare providers, previous attendees on Charminster House Seminars CPD courses and existing patients of the practice
- Other marketing
Lawful Basis:
The lawful basis for the processing of personal information relating to the provision of dental care to patients, provision of managing practice personnel, provision of dental care to patients on referral from other healthcare providers and the provision of managing referrals to and from other healthcare providers is:
- Performance of contract
- Legal obligation
The lawful basis for the provision and management of CPD courses via Charminster House Seminars is:
- Performance of contract
The lawful basis for the management of patient appointments; communicating via newsletters to existing referring healthcare providers, previous attendees on Charminster House Seminars CPD courses and existing patients of the practice; and marketing to existing referring healthcare providers, previous attendees on Charminster House Seminars CPD courses and existing patients of the practice is:
- Legitimate interest
The lawful basis for marketing otherwise is:
- Consent
The lawful basis for the processing of special category data relating to provision of dental care to patients, provision of managing practice personnel, provision of dental care to patients on referral from other healthcare providers and provision of managing patient referrals to and from other healthcare providers is:
- Performance of contract
- Legal obligations
With the conditions under Article 9(2) under GDPR of:
“processing is necessary for the purposes of preventive or occupational medicine, for the assessment of the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services on the basis of Union or Member State law or pursuant to contract with a health professional and subject to the conditions and safeguards referred to in paragraph 3;”
and
“processing is necessary for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity”.
Categories of Data Obtained:
The practice holds personal data in the following categories:
- Patient: information relating to contact details, clinical records, health records, appointment history, payment records, limited financial records, complaints record and correspondence etc. (including special category personal data)
- Information relating to the contact details of healthcare providers/dentists we accept referrals from, or refer to
- Practice personnel: information relating to contact details, recruitment details, eligibility to work in the UK details, GDC registrations, indemnity registrations, disclosure and barring service information, contracts, attendance records, holiday records, sick day records, occupational health/medical records, appraisals, disciplinary records, capability records, grievance records, correspondence with the data subject and third parties in relation to the data subjects work at the practice, pay records, bank details, national insurance number etc. (including special category personal data)
- Information relating to the contact details, professional details, payment records, limited financial records and correspondence records of attendees on Charminster House Seminars CPD courses.
- Cookies used on the practice website
How Data is Obtained:
In most instances, personal data and special category personal data is received directly from the data subject themselves (e.g. patients, practice personnel, referring healthcare providers, attendees on Charminster House Seminars CPD courses).
In some instances, personal data and special category personal data may be received from third parties (e.g. referring healthcare providers, disclosure and barring service, regulatory bodies, indemnity providers, dental insurance providers, NHS, legal representatives, website cookies etc.)
The Recipients:
Relevant practice personnel of Charminster House Dental Practice
Transfer of Data:
Patients of the practice and patients on referral from other healthcare providers
Data is stored on our internal server and is backed up via a tape based system and via a cloud service which is based in the EU.
It may be necessary for third parties to access this data such as dental software providers, IT support companies, cloud back up providers, email providers, website developers and website hosts.
It may be necessary to share this information with organisations such as other healthcare providers when a referral is made or received, dental laboratories when dental prostheses are needed, indemnity providers if needed, regulatory bodies if needed, dental insurance providers, NHS, appointment reminder texting companies, debt collection companies, legal representatives if needed, prospective practice owners etc.
Other than this data is kept confidential.
Practice personnel
Data is stored on our internal server and is backed up via a tape based system and via a cloud service which is based in the EU.
It may be necessary for third parties to access this data e.g. IT support companies, cloud back up providers, email providers etc.
It may be necessary to share this information with organisations such as pension providers, HMRC, human resources support, payroll support, insurers, accountants, legal representatives if needed, indemnity providers if needed, regulatory bodies if needed, prospective practice owners, in connection with providing a reference to a future employer etc.
Other than this data is kept confidential
Referring healthcare providers
Data is stored on our internal server and is backed up via a tape based system and via a cloud which is based in the EU.
It may be necessary for third parties to access this data such as dental software providers, IT support companies, cloud back up providers, email providers, website developers and website hosts.
It may be necessary to share this information with organisations such as other healthcare providers when a referral is made or received, indemnity providers if needed, regulatory bodies if needed, dental insurance providers, NHS, legal representatives if needed, prospective practice owners etc.
Attendees on Charminster House Seminars CPD courses
Data is stored on our internal server and is backed up via a tape based system and via a cloud which is based in the EU.
It may be necessary for third parties to access this data such as dental software providers, IT support companies, cloud back up providers, email providers, website developers and website hosts.
It may be necessary to share this information with organisations such as HMRC, insurers, accountants, legal representatives if needed.
Data Opt-Out Policy
(England)
How the NHS and care services use your information
Charminster Dental Care Ltd is one of many organisations working in the health and care system to improve care for patients and the public. Whenever you use a health or care service, such as attending Accident & Emergency or using Community Care services, important information about you is collected in a patient record for that service. Collecting this information helps to ensure you get the best possible care and treatment. The information collected about you when you use these services can also be used and provided to other organisations for purposes beyond your individual care, for instance to help with:
- Improving the quality and standards of care provided
- Research into the development of new treatments
- Preventing illness and diseases
- Monitoring safety
- Planning services
This may only take place when there is a clear legal basis to use this information. All these uses help to provide better health and care for you, your family and future generations. Confidential patient information about your health and care is only used like this where allowed by law.
Most of the time, anonymised data is used for research and planning so that you cannot be identified in which case your confidential patient information isn’t needed.
You have a choice about whether you want your confidential patient information to be used in this way. If you are happy with this use of information you do not need to do anything. If you do choose to opt out your confidential patient information will still be used to support your individual care. To find out more or to register your choice to opt out, please visit www.nhs.uk/your-nhs-data-matters. On this web page you will:
- See what is meant by confidential patient information
- Find examples of when confidential patient information is used for individual care and examples of when it is used for purposes beyond individual care
- Find out more about the benefits of sharing data
- Understand more about who uses the data
- Find out how your data is protected
- Be able to access the system to view, set or change your opt-out setting
- Find the contact telephone number if you want to know any more or to set/change your opt-out by phone
- See the situations where the opt-out will not apply
You can also find out more about how patient information is used at: https://www.hra.nhs.uk/information-about-patients/ (which covers health and care research); and https://understandingpatientdata.org.uk/what-you-need-know (which covers how and why patient information is used, the safeguards and how decisions are made)
You can change your mind about your choice at any time.
Data being used or shared for purposes beyond individual care does not include your data being shared with insurance companies or used for marketing purposes and data would only be used in this way with your specific agreement.
Health and care organisations have until 2020 to put systems and processes in place so they can be compliant with the national data opt-out and apply your choice to any confidential patient information they use or share for purposes beyond your individual care.
Our practice only uses your personal health data to provide individualised care to you and does not disclose your data for any other purposes. The national data opt-out does not apply to our usage of your data and we are compliant with the policy.
Retention Periods:
Special category patient personal data: Minimum of 11 years after the last contact or until the patient reaches 25 years old (whichever is longer); and we may store it for longer if there is justification to do so
Practice personnel data: 6 years after the data subject has left the practice
Attendees on Charminster House Seminars CPD courses: 6 years after the course date
Cookies: Different cookies types are stored for different lengths of time. Full details can be found on the website cookie policy located at https://www.charminsterdental.co.uk/cookie-consent/
Further details on individual data retention periods are available on the practice data retention policy.
Rights of Data Subjects:
Under the GDPR data subjects have:
- The right to be informed about the personal data we hold
- The right of access to the information we hold about them
- The right to rectification of the personal data we hold if incorrect
- The right to erasure of personal data we hold- (This may not apply if there is an overriding obligation to retain data for example clinical records)
- The right to restrict processing of personal data we hold
- The right to have the data we hold transferred to someone else at their request
- The right to object to processing the data we hold about them
For data subjects who have given their consent to us marketing to them, they have the right to withdraw that consent at any time. This can be done in person, via the telephone on 01202 292 030, via the contact us form on the website at https://charminsterdental.co.uk/contact-us, by emailing reception@charminsterdental.co.uk, or by writing to Charminster House Dental Practice, 65 Wellington Road, Bournemouth, Dorset, BH8 8JL.
Queries or Concerns:
Should you have a query or a complaint about the processing of your data by the practice, then please contact Lucy Sharples, the practice manager, who will endeavour to help.
Lucy Sharples can be contacted via telephoning the practice on 01202 292 030, by emailing lucy.sharples@charminsterdental.co.uk, or by writing to Lucy Sharples, Practice Manager, Charminster House Dental Practice, 65 Wellington Road, Bournemouth, Dorset, BH8 8JL.
In the event that you have a complaint and are unhappy with our response, you can contact the Information Commissioner on 0303 123 1113 or by visiting their website at https://ico.org.uk/concerns.