New and existing patient privacy notice. Vs1.0 18/5/18
Edinburgh City Chiropractic is aware of its obligations under the General Data Protection Regulation (GDPR) and is committed to processing your data securely and transparently. This privacy notice sets out, in line with GDPR, the types of data that we hold on you. 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 previous patients of the clinic
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 The Directors, Edinburgh City Chiropractic Ltd, 44 Rodney Street, EH7 4DX, 0131 558 3535.
Data protection principles
In relation to your personal data, we will:
process it fairly, lawfully and in a clear, transparent way
collect your data only for reasons that we find proper for the course of your treatment in ways that have been explained to you
only use it in the way that we have told you about
ensure it is correct and up to date
keep your data for only as long as we need it
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
Types of data we process
We hold different types of data about you, including:
your personal details including your name, address, date of birth, email address, phone numbers
medical or health information including any medications and surgeries
Previous injuries including car accidents
Previous conditions including their treatment
Smoking and drinking history
How we collect your data
We collect data starting with our initial consultation file and our consent for treatment forms. We record data as we proceed with regard to progress and treatment regimen.
This data is stored in secure filing cabinets and access is controlled to minimise risk of a data breach. We use a cloud based diary system that is also GDPR compliant.
Sharing your data
Your data will be shared with colleagues within the Clinic where it is necessary for them to undertake their duties.
We do not share your data with third.
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.
Where external companies have access to your data (the online diary and answer service providers), we provide written instructions to them to ensure that your data are held securely and in line with GDPR requirements. External companies 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 is usually for up to 8 years after your last visit.
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.
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. These are:
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
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. You can read more about this in our Subject Access Request policy which is available from [insert details]
the right for any inaccuracies to be corrected. If any data that we hold about you is incomplete or inaccurate, you are able to require us to correct it
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 transfer the data that we hold on you for your own purposes
the right to object to the inclusion of any information. You have the right to object to the way we use your data where we are using it for our legitimate interests
Where you have provided consent to our use of your data, you also have the unrestricted right to withdraw that consent at any time. Withdrawing your consent means that we will stop processing the data that you had previously given us consent to use. 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 reason for doing so.
If you wish to exercise any of the rights explained above, please contact:
The clinic manager, Edinburgh City Chiropractic, 44 Rodney Street, EH7 4DX
Making a complaint
The supervisory authority in the UK for data protection matters is the Information Commissioner (ICO). If you think your data protection rights have been breached in any way by us, you are able to make a complaint to the ICO.