Data Protection Policy

1 – Scope

This privacy notice (sometimes referred to as a privacy policy or privacy statement) concerns 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 UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018 and the Privacy and Electronic Communications Regulations (PECR), seek to protect and enhance the rights of UK data subjects. These rights cover the safeguarding of personal data, protection against the unlawful processing of personal data and its storage within the UK. 

1 – East Sussex Osteopaths, based at Saltley Farm, South Lane, Dallington, TN21 9NN and 26 Tower Street, Heathfield, TN21 8PB which hereafter for the purposes of this privacy notice will be referred to as the Osteopaths, is pleased to provide the following information:

2 – Who we are

The Osteopaths diagnose and treat musculoskeletal conditions. Treatments are carried out in accordance with the Institute of Osteopathy patient’s charter. The practice may also provide other treatments, about which our staff would be pleased to provide more details.

3 – Personal Data 

a) For the purposes of providing treatment Osteopaths may require detailed medical information. We will only collect what is relevant and necessary for your treatment. When you visit our practice, we will make notes which may include details concerning your health, medication, treatment and other issues affecting your musculoskeletal conditions. This data is always held securely, is not shared with anyone not involved in your treatment, although for data storage purposes it may be handled by pre-vetted staff who have all signed an integrity and confidentiality agreement. To be able to process your personal data it is a condition of any treatment that you give your explicit consent to allow Osteopaths to document and process your personal medical data. Contact details provided by you such as telephone numbers, email addresses, postal addresses may be used to remind you of future appointments, provide reports or other information concerning your treatment. 

b) For marketing purposes, the Osteopaths may also use the contact details provided by you to respond to your enquiries including making telephone contact and emailing information to you which the practice believes may be of interest to you. 

c) In making initial contact with the practice you consent to Osteopaths maintaining a marketing dialogue with you until you either opt out (which you can do at any time) or we decide to desist in promoting our services. Osteopaths may occasionally also act on behalf of its patients in the capacity of data processor, when we may promote other practitioners based at our premises, who may not be employed by us. Osteopaths do not broker your data and you can ask to be removed from our marketing database by emailing or phoning the practice using the contact details provided at the end of this privacy notice. 

d) Some basic personal data may be collected about you from the marketing forms and surveys you complete, from records of our correspondence and phone calls and details of your visits to our website, including but not limited to, personally identifying information like Internet Protocol (IP) addresses. 

e) Osteopaths’ website uses cookies, which is a string of information that a website stores on a visitor’s computer, and that the visitor’s browser provides to the website each time the visitor returns. WordPress.org uses cookies to help Osteopaths to identify and track visitors and their website access preferences. Osteopaths’ website visitors who do not wish to have cookies placed on their computers should set their browsers to refuse cookies before using Osteopaths’ website.

f) Osteopaths will only collect the information needed so that it can provide you with the services required. 

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 Osteopaths

To promote treatments for patients with all types of health problems indicated for osteopathic care. Osteopaths’ patients receive a confirmation email upon booking and a reminder text or email the day before their appointment. This is a legitimate interest for Osteopaths as we have a busy clinic and a patient not turning up or turning up at the wrong time can cause big knock-on effects to our schedule. It is also a legitimate interest to the patient, as Osteopaths have a 24-hour cancellation policy, in which the patient may be charged a full fee if they do not arrive for their appointment.

6 – Consent

Through agreeing to this privacy notice you are consenting to Osteopaths 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.

7 – Disclosure

Osteopaths will keep your personal information safe and secure, only staff 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. Osteopaths will not disclose your Personal Information unless compelled in order to meet legal obligations, regulations or valid governmental requests. The practice 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

Osteopaths 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 Data is held in the United Kingdom. Osteopaths use the secure system Cliniko to document patients’ medical records and diarize appointments. Only pre-vetted staff who have all signed an integrity and confidentiality agreement can access our Cliniko system, and only Chantal Prince, Callum Gaterell and Sarahjane Prince are able to access all patient medical notes.
All written information is stored alphabetically as paper notes in locked filing cabinets in the clinic treatment rooms. If a home or yard visit is conducted, they always stay with the practitioner, until returned to the locked filing cabinet at the end of the day. Archived notes are also stored in the same place for access.  In the event of clinic closure or death of the data processor/controller, the following arrangements are in place for patients to access their records: Upon patients written requests, other colleges/present receptionist, or the Osteopaths data controller’s mother: Sarahjane Prince (Massage Therapist) will have access to the filing cabinets and data. In the event of Osteopaths being sold the future owner will have the legal duty to comply with this data protection policy. Any photos taken on password protected clinic software, will be deleted once their course of treatment has been conducted and patient’s progress has been shown to the patient and documented in their patient records, unless written permission by the patient is provided for their use in promotion and advertising for Osteopaths.

10 – Your rights as a data subject

At any point whilst Osteopaths is in possession of, or processing your personal data, all data subjects have the following rights:

In the event that Osteopaths 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 Osteopaths can confirm what information it holds about you and how it is processed.

11 – You can request the following information:

12 – To access what personal data is held, identification will be required

Osteopaths will accept the following forms of 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 Osteopaths is dissatisfied with the quality, further information may be sought before personal data can be released.

All requests should be made to info@eastsussex-osteopaths.co.uk or by phoning +44 (0) 7762576492 or writing to us at the address further below.

13 – Complaints

In the event that you wish to make a complaint about how your personal data is being processed by Osteopaths 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:

Chantal prince 

East Sussex Osteopaths  

Telephone +44 (0) 7762576492 or email: info@eastsussex-osteopaths.co.uk

ICO

Wycliffe House, Water Lane, Wilmslow, SK9 5AF

Telephone +44 (0) 303 123 1113 or email: https://ico.org.uk/global/contact-us/email/

First issued March 29 2018, Updated February 19 2021 V2