Privacy

This privacy policy sets out how The Richer Health Clinic uses and protects any information that you give to us when you use this website and when visiting our clinic.

The Richer Health Clinic is committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using this website or direct contact, then you can be assured that it will only be used in accordance with this privacy statement. The Richer Health Clinic may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes. This policy is effective from 22nd May 2018.

Version 1.0
Date: 22/05/2018

The Richer Health Clinic patient privacy statement 

The Richer Health Clinic is aware of its obligations under the General Data Protection Regulation (GDPR) and is committed to protecting the privacy and security of your personal information. This privacy notice describes, in line with GDPR, how we collect and use personal data about you during and after your time as a patient of this clinic. 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 former patients.

Data controller details

The Richer Health Clinic is a data controller, meaning that it determines the processes to be used when using your personal data. Our contact details are as follows: The Richer Health Clinic, 73 Penshurst Gardens, Edgware HA8 9TT.  Tel: 020 8958 9994. Email: sandyricher@hotmail.co.uk

Data protection principles

In relation to your personal data, we will comply with data protection law. This says that the personal information we hold about you must be:

  • processed fairly, lawfully and in a clear, transparent way
  • collected only for valid reasons that we find proper for the course of your time as a patient and not used in any way that is incompatible with those purposes
  • only used in the way that we have told you about
  • accurate and up to date
  • kept only as long as is necessary for the purposes we outline
  • 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
  • kept securely

 Types of information we hold about you

Personal data or information means any information about an individual from which that person can be identified. It does not include data where the identity has been removed.

We hold many types of data about you, including:

  • your personal details including your name, address, date of birth, email address, phone numbers
  • gender
  • marital status
  • next of kin and their contact numbers
  • personal medical or health information, including past medical history
  • information concerning examination and treatment at your first and subsequent visits
  • letters of referral to or from the clinic regarding your treatment with us.

Special categories of data

There are “special categories” of more sensitive personal data which require a higher level of protection, such as information about a person’s health or sexual orientation.  The only data we collect on this is in regards:

  • Health

We do not store data on sexual orientation etc.

We will use your special category data:

  • to ensure the care you receive at the clinic is appropriate to your condition
  • to determine reasonable adjustments that should be made for access to the clinic or to treatment

We must process special categories of data in accordance with more stringent guidelines. We will process special categories of data when the following applies:

  • you have given explicit consent to the processing (on our consent form)
  • we must process the data in order to carry out our legal obligations
  • we must process data for reasons of substantial public interest

Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.

As with all cases of seeking consent from you, you will have full control over your decision to give or withhold consent and there will be no consequences where consent is withheld. Consent, once given, may be withdrawn at any time. There will be no consequences where consent is withdrawn.

How we collect your data

We collect data about you in a variety of ways and this will usually start when you make an enquiry to the clinic and continue when you attend your first and subsequent appointments. At this clinic, we keep paper and electronic records. Information we write down on paper may be transferred to our electronic system. We may receive information about you from your GP or other health care provider regarding your referral or, with your permission, additional information that will help us continue with your treatment. We may also hold the results of tests that you have undertaken and that are relevant to your treatment with the clinic.

Personal data is kept in the clinic in a variety of forms.  We store your data in the following ways:

  • Paper notes: These are stored onsite in locked filing cabinets and are only accessible to approved staff and practitioners.  At times these records may be scanned onto our electronic system for storage.  When the time comes to dispose of your paper notes, in-line with our statutory regulation, these notes are destroyed using a cross shredder and professional paper disposal company.
  • Electronic communications: We use a software package to manage any letters/communications.  This software is firewall protected and all back-ups encrypted. Access is limited to staff.  The premises where your data is held is alarmed.

Why we process your data (How we will use information about you)

The law on data protection allows us to process your data for certain reasons only, these are classified as legitimate interests. Most commonly, we will use your personal information in the following circumstances:

in order for us to carry out our contract with you (your requesting treatment and our agreement to provide it constitutes a contract) which will include confirming appointments, informing you of changes to appointments or clinic arrangements, changes to facilities or services at the clinic.

  • in order to provide you with the best possible treatment by recording health and treatment information which would be in your best interest.
  • in order to carry out legally required duties such as those required by us by our government appointed regulator
  • where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests

We may use your personal information in these rare situations:

  • where we need to protect your or someone else’s interests
  • where it is needed in the public interest or for official purposes

Situations in which we will use your personal information

We need all the categories of information to primarily allow us to perform our contract of treatment with you and to enable us to comply with legal obligations.

If you do not provide your data to us

One of the reasons for processing your data is to allow us to carry out our duties in line with your contract of care with us. If you do not provide us with the data needed to do this, we will be unable to perform that care to ensure your best interests are being maintained. We may also be prevented from continuing with your treatment with us due to our legal obligations.

Change of purpose

We will only use your personal information for the purposes for which we collected it unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

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.

Sharing your data

Your data will be shared with colleagues within the Clinic but only where it is necessary for them to undertake their duties. This includes reception staff.

We may share your data with third parties in order to facilitate a referral to another healthcare practitioner, investigation, or to keep your GP informed about your progress with treatment.

We may also share your data with third parties such as your insurance company or as part of a Clinic sale or restructure, or for other reasons to comply with a legal obligation upon us. We would always keep you informed of these situations.

Transferring information outside the EU

We do not share your data with bodies outside of the European Economic Area.

Data Security – Protecting your data

We have put in place measures to protect the security of your information against accidental loss or disclosure, alteration, unauthorised access, destruction or abuse. We have implemented processes to guard against such. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.  Details regarding data security is freely available to patients.  Please enquire and we would be happy to share our Information & Data security Audits with you at a mutually convenient time.

Where we share your data with third parties, we have received written instructions from them to ensure that your data is held securely and in line with GDPR requirements. Third parties 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 will be at least for the duration of your being a patient with us and we are legally required, by the Chiropractic regulator, to keep this data for eight years after your time as a patient has ended. To determine any appropriate retention period for personal data beyond eight years we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means and the applicable legal requirements.

Once we no longer have a lawful use for retaining your information, we will dispose of it in a secure manner that maintains data security.

In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.

Your duty to inform us of changes

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your time as a patient with us.

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:

  • 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. Find out how to do this from Sandra Richer.
  • the right for any inaccuracies to be corrected. If any data that we hold about you is incomplete or inaccurate, you can require us to correct it.
  • 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. We also must inform you of any changes to how we use your data.
  • 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. However, if it falls under our legal obligation to keep your data securely for a longer period we will do so.
  • 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 request transfer of the data that we hold on you for your own purposes.

If you want to access your data, review, verify or correct your data, request we erase your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact us via email on sandyricher@hotmail.co.uk or in writing to The Richer Health Clinic, 73 Penshurst Gardens, Edgware HA8 9TT and this request will be passed onto Sandra Richer to be reviewed.  She will then contact you in writing/email.

Fees

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee for a second or subsequent copy of information, for a summarised version/report or if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances. 

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

Right to withdraw consent

Where you have provided consent to the collection, processing and transfer of your data, you have the right to withdraw that consent at any time. 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 legal reason for doing so.

To withdraw consent, contact Sandra Richer via email on sandyricher@hotmail.co.uk or in writing to The Richer Health Clinic, 73 Penshurst Gardens, Edgware HA8 9TT and this request will be passed onto Sandra Richer to be reviewed.  She will then contact you in writing/email.

Making a complaint

If you have any questions about this Privacy Notice or how we handle your information, please contact the Clinic’s Data Protection Manager who is Sandra Richer.  She can be contacted on 020 8958 9994, via email sandyricher@ hotmail.co.uk or in writing to The Richer Health Clinic, 73 Penshurst Gardens, Edgware HA8 9TT.

You have the right to make a complaint at any time to the supervisory authority in the UK for data protection matters, the Information Commissioner’s Office (ICO).

Website

Links to other websites

Our website may contain links to enable you to visit other websites of interest easily. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.

Controlling your Personal Information

You may choose to restrict the collection or use of your personal information in the following ways:

  • if you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by writing to or emailing us at sandyricher@hotmail.co.uk We will not sell, distribute or lease your personal information to third parties unless we have your permission or are required by law to do so.

 

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